Ezel / IRS Rulings / 200913061

CCA 200913061: Every partner could protest and participate in the TEFRA appeals conference

Number
200913061
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Participation in Administrative Proceedings; Waivers; Agreements
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 6224
Ruling dated
June 24, 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 partner notice and participation rights during a TEFRA administrative proceeding. The tax matters partner generally had to forward notice of the 60-day letter and appeal rights to every partner. Any partner could file a protest. All partners also could participate in the appeals conference, with the tax matters partner responsible for arranging it.

Ruling snapshot

  • Question: What notice, protest, and appeals-conference rights did partners have in the TEFRA proceeding?
  • Outcome: Advice given: the tax matters partner should forward the notice, any partner may protest, and every partner may participate in the conference.
  • Key authorities: Treas. Reg. §§ 301.6223(g)-1(b)(ii) and 301.6224(a)-1.

Full text (IRS public release)

ID: CCA-624324-08 Number: 200913061
Release Date: 3/27/2009
Office: --------------
UILC: 6224.00-00

From: -------------------
Sent: Tue 6/24/2008 3:24 PM
To: --------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------
Subject: RE: TEFRA question

--------------------------------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------------------------------------Generally the TMP is
required to forward notice of the 60 day letter and appeals rights to all partners under Treas. reg.
301.6223(g)-1(b)(ii). Any partner can file a protest. Under Treas. Reg. 301.6224(a)-1 the partners are
entitled to participate in any appeals conference with the TMP making the arrangements.

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