Ezel / IRS Rulings / 201011030

One-year assessment period begins after partner identification compliance

Number
201011030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Unidentified Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 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 one-year period under section 6229(e) begins to run for an unidentified partner. The advice stated that the period would not begin until the partner complied with section 6223(c)(3) and Treasury Regulation section 301.6223(c)-1, or possibly when the IRS linked the partner on PCS.

Ruling snapshot

  • Question: When does the one-year period under section 6229(e) begin for an unidentified partner?
  • Outcome: advice given
  • Key authorities: IRC §§ 6223(c)(3) and 6229(e); Treas. Reg. § 301.6223(c)-1

Full text (IRS public release)

ID: CCA_2010021610033937 Number: 201011030
Release Date: 3/19/2010
Office: ----------
UILC: 6229.05-00

From: -------------------
Sent: Tuesday, February 16, 2010 10:03:41 AM
To: --------------------
Cc: ------------------------------------------------------
Subject: RE: ----------one year date and unidentified investors

Yes. The one year period under section 6229(e) will not begin to run until the partner has complied with I.R.C. 6223(c)(3) and Treas. Reg. 301.6223(c)-1 or possibly when we have linked the partner on PCS.

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