Ezel / IRS Rulings / 200942046

CCA 200942046: Discretion to link indirect partners in an FPAA

Number
200942046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Information for Secretary's Notices
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 6110
Ruling dated
August 10, 2009
Publicly released
October 16, 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 states that Treas. Reg. § 301.6223(c)-1(f) permits the IRS to link indirect partners at its discretion. It adds that the IRS may do so occasionally for policy reasons. The brief advice concerns information used for an FPAA and does not provide further facts about the particular partnership.

Ruling snapshot

  • Question: May the IRS link indirect partners when issuing an FPAA?
  • Outcome: Advice given
  • Key authorities: Treas. Reg. § 301.6223(c)-1(f); IRC § 6223

Full text (IRS public release)

ID: CCA_2009081009342837 Number: 200942046
Release Date: 10/16/2009
Office: --------------
UILC: 6223.02-00

From: -------------------
Sent: Monday, August 10, 2009 9:34:32 AM
To: ---------------------
Cc: ----------------------------------
Subject: RE: FPAA ----

Treas. Reg. 301.6223(c)-1(f) allows us to link indirect partners at our own discretion. Occasionally we so
for policy reasons.

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