Ezel / IRS Rulings / 200946044

CCA 200946044: Disguised sale listed as a partnership item

Number
200946044
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partnership Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
September 25, 2009
Publicly released
November 13, 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 a disguised sale is specifically listed as a partnership item under the cited Treasury regulations. The one-sentence email does not analyze the underlying transaction or reach a taxpayer-specific result.

Ruling snapshot

  • Question: Is a disguised sale a partnership item under the cited regulations?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(3)-1

Full text (IRS public release)

ID: CCA_2009092510582137 Number: 200946044
Release Date: 11/13/2009
Office: ----------
UILC: 6231.03-00

From: -------------------
Sent: Friday, September 25, 2009 10:58:30 AM
To: ----------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------------------
Subject: RE: Partnership item: ---------

A disguised sale is also specifically listed as a partnership item under Treas. Reg. 301.6231(a)(3)-
1(a)(4)(iii) and -1(c)(4).

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