Ezel / IRS Rulings / 200848035

CCA 200848035: Consolidated-group letter may be sent only to parent

Number
200848035
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Privilege to File Consolidated Returns (May v. May Not File Consolidated Return)
Topics
Corporate transactions and reorganizations
Code sections
§ 1501
Ruling dated
July 14, 2008
Publicly released
November 28, 2008
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 2008, 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 2008
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

The subject line concerns a 60-day objection letter, but the released email omits the question. Chief Counsel advised that sending the letter to the subsidiary partner was unnecessary and that it could be sent only to the consolidated parent. A courtesy copy could be sent to the subsidiary if desired.

Ruling snapshot

  • Question: Must the unidentified 60-day objection letter also be sent to the subsidiary partner?
  • Outcome: Advice given. No; send it to the parent, with an optional courtesy copy to the subsidiary.
  • Key authorities: No authority is cited in the released email.

Full text (IRS public release)

1

ID: CCA-714143-08 Number: 200848035
Office: --------------
Release Date: 11/28/2008

UILC: 1501.00-00

From: -------------------
Sent: Mon 7/14/2008 2:35 PM
To: --------------------
Cc: -------------------------------------------------------------------------------------------------------------------
Subject: RE: 60 Day Objection letter

Its not necessary. You can send them to the parent only. But you are free to send a courtesy copy to the
sub partner if you want.

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