Ezel / IRS Rulings / 200912032

CCA 200912032: A parent signed for every severally liable member of its consolidated group

Number
200912032
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Regulations Governing Consolidated Returns (May v. May Not File Consolidated Returns)
Topics
Corporate transactions and reorganizations
Code sections
§ 1502
Ruling dated
February 24, 2009
Publicly released
March 20, 2009
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 2009, 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 2009
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

Chief Counsel addressed the capacity in which a parent corporation signed in a TEFRA matter involving a subsidiary that was a partner. The parent was not signing only for that partner-subsidiary. Technically, it signed on behalf of every member of the consolidated group, each of which was severally liable. The redacted email provides no further facts about the document being signed or the underlying partnership matter.

Ruling snapshot

  • Question: Did a consolidated group's parent sign only for the partner-subsidiary or for every group member?
  • Outcome: Advice given: the parent signed for all severally liable members of the consolidated group.
  • Key authorities: IRC § 1502 consolidated-return rules.

Full text (IRS public release)

ID: CCA_2009022411370337 Number: 200912032
Release Date: 3/20/2009
Office: --------------
UILC: 1502.00-00

From: -------------------
Sent: Tuesday, February 24, 2009 11:37:05 AM
To: ----------------------
Cc: ------------------------------------
Subject: RE: TEFRA Questions ---------

Technically the parent is signing on behalf of all members of the consolidated group who are all severally
liable. Its not just signing for the partner-sub. -------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------

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