Ezel / IRS Rulings / 200953023

CCA 200953023: Treat cooperative associations as C corporations for small-partnership exception

Number
200953023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Exception for Small Partnerships
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
December 9, 2009
Publicly released
January 1, 2010
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 2010, 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 2010
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

Chief Counsel advice addressed how cooperative associations should be treated for purposes of the small partnership exception. Based on advice from an undisclosed source, Counsel recommended treating cooperative associations as C corporations for that purpose.

Ruling snapshot

  • Question: How should cooperative associations be classified for purposes of the small partnership exception?
  • Outcome: Advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2009120909480954 Number: 200953023
Release Date: 12/31/2009
Office: --------------
UILC: 6231.01-01

From: --------------------------
Sent: Wednesday, December 09, 2009 9:48:10 AM
To: -------------------
Cc: --------------------------------------------
Subject: RE: Cooperative Associations = C Corporations?

Upon advice from --------------, we recommend treating cooperative associations as C corporations for
purposes of the small partnership exception.

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