Ezel / IRS Rulings / 200913041

CCA 200913041: Converted partnership items were no longer subject to TEFRA

Number
200913041
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Items Cease to Be Partnership Items in Certain Cases
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
September 29, 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 addressed a parent-subsidiary consent issue involving items that had been partnership items. The advice states that once those items converted to nonpartnership items, they were no longer governed by the TEFRA partnership procedures. The writer also agreed with a second conclusion presented by the recipient, while noting that the proposed step arguably was unnecessary. Extensive redactions prevent a more specific description of that second conclusion.

Ruling snapshot

  • Question: Did TEFRA continue to apply after partnership items became nonpartnership items, and was a proposed second step needed?
  • Outcome: Advice given: TEFRA no longer applied, and the writer agreed with the second conclusion while questioning whether the step was necessary.
  • Key authorities: IRC § 6231; TEFRA partnership procedures.

Full text (IRS public release)

ID: CCA-929943-08 Number: 200913041
Release Date: 3/27/2009
Office: --------------
UILC: 6231.13-00

From: -------------------
Sent: Mon 9/29/2008 9:43 AM
To: -----------------
Cc: ----------------------------------------------------------------------
Subject: RE: Parent-Subsidiary Consent Issue

(1) Once the partnership items converted to nonpartnership items, they are no longer subject to the
TEFRA provisions. ------------------------------------------------------------------------------------------------------------------
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(2) I agree with your second conclusion, although arguably it would not be necessary.

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