Ezel / IRS Rulings / 201005050

CCA 201005050: A timely FPAA keeps the statute open for an unidentified indirect partner

Number
201005050
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Unidentified Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
January 13, 2010
Publicly released
February 5, 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

This internal IRS Chief Counsel advice addresses the limitations period for an indirect partner whose identity is not yet known. It concludes that when the partner is an unidentified indirect partner and the IRS timely issues an FPAA, IRC § 6229(e) keeps the statute open for that partner until at least one year after the partner is identified.

Ruling snapshot

  • Question: How does a timely FPAA affect the limitations period for an unidentified indirect partner?
  • Outcome: Advice given.
  • Key authorities: IRC § 6229(e).

Full text (IRS public release)

ID: CCA_2010011316282937 Number: 201005050
Release Date: 2/5/2010
Office: ----------
UILC: 6229.05-00

From: -------------------
Sent: Wednesday, January 13, 2010 4:28:31 PM
To: --------------------
Cc: -----------
Subject: RE: 25% Omission of Income

If the partner is an unidentified indirect partner and we timely issued an FPAA, section 6229(e) keeps the
statute open for the unidentified partner at least until one year after he is identified.

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