Ezel / IRS Rulings / 200302001

CCA 200302001: Advice on a TEFRA partnership settlement, largely redacted

Number
200302001
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
July 15, 2002
Publicly released
January 10, 2003
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2003, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2003
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Field counsel asked National Office counsel to evaluate the hazards of contesting a settlement involving TEFRA partnership items. The released memorandum identifies section 6229 in its heading. Its substantive hazards discussion is covered by black redactions across the published pages. The public text therefore does not disclose the settlement facts, analysis, or recommended position.

Ruling snapshot

  • Question: What are the hazards of contesting the settlement of the partnership case?
  • Outcome: Advice given, but the substantive advice is redacted in the public release.
  • Key authorities: IRC § 6229 is identified in the heading; no substantive authority is visible.

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
I N T E R N AL R E V E N U E S E R V I C E WASHINGTON, D.C. 20224

OFFICE OF
CHIEF COUNSEL

July 15, 2002

Number: 200302001
Release Date: 01/10/2003
CC:PA:APJP:3
POSTF-161710-01
UILC: 6229.02-00

INTERNAL REVENUE SERVICE NATIONAL OFFICE LEGAL ADVICE

MEMORANDUM FOR ASSOCIATE AREA COUNSEL, LMSB (SEATTLE) CC:LM:CTM:SEA

FROM: Susan Mosley
Senior Technician Reviewer
CC:PA:APJP:3

SUBJECT: Resolution of TEFRA partnership items.

This Chief Counsel Advice responds to your memorandum dated April 16, 2002. In accordance with I.R.C. § 6110(k)(3), this Chief Counsel Advice should not be cited as precedent.

LEGEND

X=

Year 1=
Year 2=

You have asked for assistance in evaluating the hazards of contesting the settlement of the subject case. We rely on the facts you have provided both in your incoming request for advice and in your informal requests for assistance.
2

HAZARDS AND OTHER CONSIDERATIONS

1

1
3
4

This writing may contain privileged information. Any unauthorized disclosure of this
writing may have an adverse effect on privileges, such as the attorney client
privilege. If disclosure becomes necessary, please contact this office for our views.

Please call if you have any further questions.

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