Ezel / IRS Rulings / 200948044

CCA 200948044: Parent and subsidiary should execute a new Form 870-LT

Number
200948044
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Settlement Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6224, § 6229, § 6110
Publicly released
November 27, 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 TEFRA entity and a settlement agreement. Because the parent’s signature is necessary and the limitations period remains open, Counsel recommends that both the parent and subsidiary execute a new Form 870-LT. The advice cites IRM 8.19.3.8.6(5).

Ruling snapshot

  • Question: Who should execute a new Form 870-LT when a parent’s signature is necessary and the limitations period remains open?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6224 and 6229; Form 870-LT; IRM 8.19.3.8.6(5)

Full text (IRS public release)

ID: CCA_2009100816264054 Number: 200948044
Release Date: 11/27/2009
Office: --------------
UILC: 6224.01-01

From: --------------------------
Sent: Thursday, October 08, 2009 4:26:40 PM
To: -----------------------------------------
Cc: ----------------------------------------------
Subject: RE: TEFRA entity

As the parent's signature is necessary and the limitations period remains open, we recommend having
both parent and subsidiary execute a new Form 870-LT. See IRM 8.19.3.8.6(5).

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