Ezel / IRS Rulings / 201014065

CCA 201014065: IRS advises using the partnership's correct EIN on a consent

Number
201014065
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
March 9, 2010
Publicly released
April 9, 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 addresses the employer identification number to use on a partnership consent. It recommends using the partnership's correct EIN so that the partnership involved is correctly identified. The advice also notes that Rev. Rul. 2004-88 provides that a disregarded entity may be the tax matters partner if it qualifies as a general partner under state law.

Ruling snapshot

  • Question: Which EIN should be used on a consent involving a partnership?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Rev. Rul. 2004-88

Full text (IRS public release)

ID: CCA_2010030913483137 Number: 201014065
Release Date: 4/9/2010
Office: ----------
UILC: 6231.07-00

From: -------------------
Sent: Tuesday, March 09, 2010 1:48:33 PM
To: ---------------------
Cc: -----------
Subject: RE: Consent Question

I suggest using the partnership's correct EIN on a consent since the object is to correctly identify the
partnership in issue.

Rev. Rul. 2004-88 provides that a disregarded entity may be the TMP if it qualifies as a general partner
under state law.

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