Ezel / IRS Rulings / 200947046

CCA 200947046: Effect of a tax matters partner agreement on direct partners

Number
200947046
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Binds All Partners
Topics
Procedure, penalties, and administration
Code sections
§ 6224, § 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 addresses a tax matters partner agreement in a partnership with more than 100 direct partners. It states that the agreement binds direct partners who hold less than a one-percent interest.

Ruling snapshot

  • Question: Which direct partners are bound by a tax matters partner agreement when a partnership has more than 100 direct partners?
  • Outcome: Advice given
  • Key authorities: IRC § 6224

Full text (IRS public release)

ID: CCA_2009101309305537 Number: 200947046
Release Date: 11/20/2009
Office: ----------
UILC: 6224.01-03

From: -------------------
Sent: Tuesday, October 13, 2009 9:31:00 AM
To: -------------------
Cc: -----------
Subject: RE: Tefra agreement question

If the partnership has more than 100 direct partners, the TMP agreement binds those direct partners with
less than a 1 percent interest.

What does the Code say today, for your facts?

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