Ezel / IRS Rulings / 201007054

A normal Form 872 covers non-TEFRA partnership items

Number
201007054
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Assessment and Collection (Barred v. Not Barred)
Topics
Procedure, penalties, and administration
Code sections
§ 6501, § 6501(c), § 6221, § 6231, § 6110, § 6110(k)(3)
Ruling dated
January 14, 2010
Publicly released
February 19, 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 advised that a normal Form 872 consent to extend the assessment period covered items from partnerships that were not subject to the TEFRA provisions. The advice addressed the wording of a consent and a possible TEFRA issue, but provided no further facts or analysis.

Ruling snapshot

  • Question: Does a normal Form 872 cover items from partnerships outside the TEFRA provisions?
  • Outcome: Advice given.
  • Key authorities: The advice concerns the assessment period and the TEFRA provisions; no specific Code section beyond the listed UILC is quoted in the release.

Full text (IRS public release)

ID:       CCA_2010011409385237                        Number: 201007054
                                                      Release Date: 2/19/2010
Office: ----------
UILC:     6501.00-00


From: -------------------
Sent: Thursday, January 14, 2010 9:38:53 AM
To: ------------------------
Cc: -----------
Subject: RE: Wording of consent and possible TEFRA issue

I agree that you are covered by a normal Form 872 for items from partnerships that are not subject to the
TEFRA provisions.

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