Ezel / IRS Rulings / 200947049

CCA 200947049: LLC manager's signature on a partnership return

Number
200947049
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Signing of Partnership Returns
Topics
Procedure, penalties, and administration
Code sections
§ 6063, § 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 considers whether an owner of an LLC's general partner may sign the partnership's Form 1065. It states that if the owner is also a manager of the LLC, the signature may be treated as made in a representative capacity for the general-partner LLC and may comply with IRC § 6063. The advice cites Pleasanton Gravel and Three G Trading.

Ruling snapshot

  • Question: May an LLC manager's signature on Form 1065 be treated as the signature of the LLC general partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6063; Pleasonton Gravel v. Commissioner, 85 T.C. 839 (1985)

Full text (IRS public release)

ID: CCA_2009100611231937 Number: 200947049
Release Date: 11/20/2009
Office: ----------
UILC: 6063.00-00

From: -------------------
Sent: Tuesday, October 06, 2009 11:23:29 AM
To: -----------------------------------------------
Cc: ------------------------------------------------------
Subject: RE: Per our phone call

If the owner of the LLC general partner was also a manager of that LLC, his signature on the Form
1065 may be deemed to have been made in a representative capacity on behalf of the general partner
LLC and thus comply with I.R.C. 6063. See Pleasonton Gravel v. Commissioner, 85 T.C. 839 (1985) and
Three G Trading, T.C. Memo. 1988-131.

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