Ezel / IRS Rulings / 201013040

CCA 201013040: IRS approves use of Form 13798-L to designate a TMP

Number
201013040
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
February 26, 2010
Publicly released
April 2, 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 approved a proposed approach concerning designation of a tax matters partner in a TEFRA matter. It clarified that Form 13798-L is the form used to designate a tax matters partner.

Ruling snapshot

  • Question: Which form is used to designate a tax matters partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Form 13798-L

Full text (IRS public release)

ID: CCA_2010022609193237 Number: 201013040
Release Date: 4/2/2010
Office: ----------
UILC: 6231.07-00

From: -------------------
Sent: Friday, February 26, 2010 9:19:36 AM
To: ----------------------
Cc: -----------------------------------
Subject: RE: TEFRA TMP Issue

Approved. Note that Form 13798-L is the form used to designate a TMP.

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