Ezel / IRS Rulings / 200914042

CCA 200914042: A tax matters partner's failure did not invalidate the TEFRA proceeding

Number
200914042
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Additional Administration Provisions
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
March 9, 2009
Publicly released
April 3, 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 TEFRA partnership-proceeding issue, but the opening portion of the released answer was redacted. The remaining text relies on section 6230(f). It explains that a tax matters partner's failure to forward a notice or perform an act does not affect the proceeding's applicability to the partners. The released email supplies no further facts about the particular failure or notice at issue.

Ruling snapshot

  • Question: Did a tax matters partner's failure to forward a notice or perform a required act prevent the TEFRA proceeding from applying to the partners?
  • Outcome: Advice given: no, section 6230(f) preserves the proceeding's applicability.
  • Key authorities: IRC § 6230(f).

Full text (IRS public release)

ID: CCA_2009030909360437 Number: 200914042
Release Date: 4/3/2009
Office: --------------
UILC: 6230.00-00

From: -------------------
Sent: Monday, March 09, 2009 9:36:06 AM
To: -------------------
Cc: ---------------------------------------------------------------------------------
Subject: RE: PTP's and T.R. 301.6223

----------------------------------------------------------------------. Section 6230(f) provides that any failure of the
TMP to forward any notice or perform any act does not affect the applicability of the TEFRA proceeding to
the partners.

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