Ezel / IRS Rulings / 200945062

Form 870-PT covers the full partnership year for the signing partner

Number
200945062
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Request for Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6227
Ruling dated
September 21, 2009
Publicly released
November 6, 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

Counsel advised that Form 870-PT is a comprehensive closing agreement for the entire partnership taxable year for the partner who signs it. Items not adjusted in that agreement remain as originally reported on the partnership's original Form 1065. The advice distinguishes Form 870-PT from non-TEFRA Forms 870, which may be only waivers.

Ruling snapshot

  • Question: What does a signed Form 870-PT cover, and how does it differ from a non-TEFRA Form 870?
  • Outcome: Advice given
  • Key authorities: Form 870-PT; Form 1065; non-TEFRA Forms 870

Full text (IRS public release)

ID: CCA_2009092111355037 Number: 200945062
Release Date: 11/6/2009
Office: ----------
UILC: 6227.02-00

From: -------------------
Sent: Monday, September 21, 2009 11:35:56 AM
To: --------------------
Cc: ---------------------------------
Subject: RE: ---------

A Form 870-PT is a comprehensive closing agreement for the entire partnership taxable year for the partner signing the agreement. Anything not adjusted in the Form 870-PT will remain as originally reported on the original Form 1065. It is different in this respect from the non-TEFRA Forms 870 which may be mere waivers.

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

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