Ezel / IRS Rulings / 200947044

CCA 200947044: Partnership treatment of a contribution outside TEFRA

Number
200947044
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Publicly released
November 20, 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 Roberts v. Commissioner governs a question concerning a partnership contribution. It says that, absent a TEFRA proceeding to redetermine the partnership's treatment, both the taxpayer and the government are bound by how the partnership treated the contribution.

Ruling snapshot

  • Question: Are the taxpayer and government bound by a partnership's treatment of a contribution when no TEFRA proceeding redetermined that treatment?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Roberts v. Commissioner, 94 T.C. 853 (1990)

Full text (IRS public release)

ID: CCA_2009100716264037 Number: 200947044
Release Date: 11/20/2009
Office: ----------
UILC: 6231.05-00

From: -------------------
Sent: Wednesday, October 07, 2009 4:26:45 PM
To: ---------------
Cc: -----------------------------
Subject: RE: Non-Partnership or Affected Item

The case is governed by Roberts v. Commissioner, 94 T.C. 853 at 860 (1990). Both taxpayer and the
government are bound by how the partnership treated the contribution in the absence of a TEFRA
proceeding to redetermine the partnership's treatment.

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