Ezel / IRS Rulings / 200914043

CCA 200914043: Form 872-P/O signature requirements changed after June 27, 2004

Number
200914043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Common Parent Agent for Subsidiaries
Topics
Corporate transactions and reorganizations
Code sections
§ 1502
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 reviewed who needed to sign a Form 872-P/O involving a subsidiary and parent. For tax years beginning before June 28, 2004, the advice said both the subsidiary and parent should sign. For years beginning after that date, only the subsidiary tax matters partner had to sign. The email stated that the remainder of the submission looked satisfactory but supplied no further facts.

Ruling snapshot

  • Question: Who had to sign the Form 872-P/O for years beginning before and after June 28, 2004?
  • Outcome: Advice given: both subsidiary and parent should sign for the earlier years, while only the subsidiary tax matters partner must sign for the later years.
  • Key authorities: IRC § 1502; Form 872-P/O.

Full text (IRS public release)

ID: CCA_2009030911393837 Number: 200914043
Release Date: 4/3/2009
Office: --------------
UILC: 1502.77-00

From: -------------------
Sent: Monday, March 09, 2009 11:39:43 AM
To: --------------------
Cc: ------------------------------------
Subject: RE: Form 872-P/O

I think the sub and parent both should sign for years beginning before June 28, 2004.

Only the sub-TMP has to sign for years after the above date.

The rest looks O.K.

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