Ezel / IRS Rulings / 200922052

CCA 200922052: Delegation Order 4-19 covered partnership-item settlements regardless of form

Number
200922052
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Settlement Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
April 29, 2009
Publicly released
May 29, 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 procedures for a case in which a pass-through partner wanted to agree and pay. The email stated that Delegation Order 4-19 covered all settlement agreements involving partnership items, regardless of the document's title. It expressly listed Forms 870-PT, 870-LT, 866, and 906, along with other documents settling partnership items. The visible advice therefore tied the delegation's scope to the substance of the settlement rather than the form used; the remaining discussion was redacted.

Ruling snapshot

  • Question: Did Delegation Order 4-19 cover partnership-item settlements made on different forms?
  • Outcome: Advice given: the order covered all partnership-item settlement agreements regardless of title.
  • Key authorities: Delegation Order 4-19.

Full text (IRS public release)

ID: CCA_2009042909313637 Number: 200922052
Release Date: 5/29/2009
Office: --------------
UILC: 6224.01-01

From: -------------------
Sent: Wednesday, April 29, 2009 9:31:38 AM
To: -------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------
Subject: RE: Procedures For Cases Where Pass-through Partner Wants to Agree and Pay ---------

Del Order 4-19 covers all settlement agreements of partnership items regardless of the title. Thus, it
currently covers the Forms 870-PT, 870-LT, 866, 906, and any other settlement document of partnership
items. ----------------------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace