Ezel / IRS Rulings / 200913015

CCA 200913015: Practice for sending a TEFRA notice to IDRS and Schedule K-1 addresses

Number
200913015
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice to Partners of Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6223
Ruling dated
June 19, 2008
Publicly released
March 27, 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 described a practice for sending a TEFRA notice to a partner. The notice was first sent only to the partner's last known address in the IRS system. The Schedule K-1 address was used if the notice sent to the system address was returned. The heavily redacted release does not identify whose practice was described or provide further legal analysis.

Ruling snapshot

  • Question: What address was used when sending a TEFRA proceeding notice to a partner?
  • Outcome: Advice given. The release describes a practice of issuing the notice to the last known IDRS address first and sending it to the Schedule K-1 address if the first notice is returned.
  • Key authorities: IRC § 6223 notice rules.

Full text (IRS public release)

ID: CCA-619907-08 Number: 200913015
Release Date: 3/27/2009
Office: --------------
UILC: 6223.00-00

From: -------------------
Sent: Thu 6/19/2008 9:07 AM
To: --------------------
Cc: -------------------------------------------------------------------------------------------------------------------
Subject: RE: TEFRA Proceedings returned NBAP

----------------------------------------------------------------------------------------Their practice, however, has been to
issue it only to the last known address per IDRS and only send it to the K-1 address if the notice to the
IDRS address is returned

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