Ezel / IRS Rulings / 200943035

CCA 200943035: Valid tax matters partner designations must follow the regulations

Number
200943035
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
June 23, 2009
Publicly released
October 23, 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 comments on a proposed response concerning the designation of a partnership's tax matters partner. It states that a valid designation made outside the partnership return must comply with Treas. Reg. § 301.6231(a)(7)-1(e) and the related paragraph ending in “-2.” The released advice does not provide further facts or analysis.

Ruling snapshot

  • Question: What regulation governs a valid tax matters partner designation made outside the partnership return?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(7)-1(e) and -2

Full text (IRS public release)

-------------------

ID: CCA_2009062315210037 Number: 200943035
Release Date: 10/23/2009
Office: --------------
UILC: 6231.07-00

From: -------------------
Sent: Tuesday, June 23, 2009 3:21:02 PM
To: ---------------------
Cc: -----------
Subject: FW: Requesting your comments

This is fine as far as it goes. You might mention that a valid designation, if not made on
the partnership return, must be made in accordance with Treas. Reg. 301.6231(a)(7)-
1(e) and –2

Attachment: [Redacted]

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