Ezel / IRS Rulings / 201016057

CCA 201016057: A pass-through partner can bind indirect partners through a section 6224 agreement

Number
201016057
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Settlement Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
March 11, 2010
Publicly released
April 23, 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 states that a pass-through partner can sign an agreement binding indirect partners under section 6224(c)(1). When the settling partner is a tier, only its general partner or tax matters partner needs to sign. If a source partnership wants to pay the tax for its partners, the tax matters partner and notice partners should agree because the tax matters partner has authority to bind only non-notice partners.

Ruling snapshot

  • Question: Who must sign a section 6224 agreement when a pass-through or source partnership is settling on behalf of partners?
  • Outcome: Advice given
  • Key authorities: IRC § 6224(c)(1)

Full text (IRS public release)

ID: CCA_2010031113083337 Number: 201016057
Release Date: 4/23/2010
Office: ----------
UILC: 6224.01-01

From: -------------------
Sent: Thursday, March 11, 2010 1:08:38 PM
To: --------------------------------------------------------------
Cc: ----------------------------------
Subject: RE: Agreements

A pass-thru partner can sign an agreement binding the indirect partners. I.R.C. 6224(c)(1)(last
sentence). Since your settling partner is a tier, only its general partner/TMP need to sign.

For a source partnership that wants to pay the tax for is partners, the TMP and notice partners should
agree since the TMP only has power to bind non-notice partners

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