Ezel / IRS Rulings / 201011027

Section 6229(e)(2)(B) coverage depends on a timely FPAA or inconsistent filing

Number
201011027
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Unidentified Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
February 16, 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 addressed when the IRS was covered by section 6229(e)(2)(B) in connection with unidentified investors. The advice stated that the provision applied only if the IRS issued an FPAA timely or the indirect partners filed inconsistently with the partnership return and failed to include a Form 8082 notice of inconsistent treatment with their returns.

Ruling snapshot

  • Question: When does section 6229(e)(2)(B) cover the IRS in an unidentified-investor matter?
  • Outcome: advice given
  • Key authorities: IRC § 6229(e)(2)(B); Form 8082

Full text (IRS public release)

ID: CCA_2010021609275037 Number: 201011027
Release Date: 3/19/2010
Office: ----------
UILC: 6229.05-00

From: -------------------
Sent: Tuesday, February 16, 2010 9:27:53 AM
To: --------------------
Cc: --------------------------------------------------------------------------------------------------
Subject: RE: ----------one year date and unidentified investors

We are covered by section 6229(e)(2)(B) only if we issued an FPAA timely or the indirect partners filed inconsistently with the partnership return and failed to include a notice of inconsistent treatment (Form 8082) with their returns.

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