Ezel / IRS Rulings / 200941025

CCA 200941025: A small partnership may elect to be governed by TEFRA

Number
200941025
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions and Special Rules; Exception for Small Partnerships
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
August 31, 2009
Publicly released
October 9, 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

This Chief Counsel advice reviews a draft concerning the TEFRA partnership rules. It recommends adding that a small partnership can elect to be governed by TEFRA. The message comments on draft language and does not decide a particular taxpayer's liability or describe a specific partnership's facts.

Ruling snapshot

  • Question: Should a draft state that a small partnership can elect to be governed by TEFRA?
  • Outcome: Advice given.
  • Key authorities: IRC § 6231; IRC § 6110(k)(3).

Full text (IRS public release)

ID: CCA_2009083115112537 Number: 200941025
Release Date: 10/9/2009
Office: --------------
UILC: 6231.00-00, 6231.01-01

From: -------------------
Sent: Monday, August 31, 2009 3:11:29 PM
To: ---------------------
Cc:
Subject: FW: IVT - TEFRA

Looks good. I might add that a small partnership can elect to be governed by TEFRA in paragraph 1.

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