Ezel / IRS Rulings / 201011023

Tax matters partner may file as notice partner if qualified

Number
201011023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Petition by Other Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6226
Ruling dated
February 4, 2010
Publicly released
March 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 advice stated that a tax matters partner could file as a notice partner if the partner met all requirements for being a tax matters partner. The advice cited Barbados #6 v. Commissioner, 85 T.C. 900 (1985).

Ruling snapshot

  • Question: May a tax matters partner file as a notice partner when the partner meets all tax matters partner requirements?
  • Outcome: advice given
  • Key authorities: IRC § 6226; Barbados #6 v. Commissioner, 85 T.C. 900 (1985)

Full text (IRS public release)

ID: CCA_2010020411304337 Number: 201011023
Release Date: 3/19/2010
Office: ----------
UILC: 6226.02-00

From: -------------------
Sent: Thursday, February 04, 2010 11:30:50 AM
To: --------------------
Cc: -----------
Subject: RE: TEFRA

The TMP can file as a notice partner if he meets all the requirements for a TMP. Barbados #6 v. Commissioner, 85 T.C. 900 (1985)

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