Ezel / IRS Rulings / 201017053

CCA 201017053: Tier entity may sign a closing agreement as a pass-through partner

Number
201017053
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Settlement Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
April 1, 2010
Publicly released
April 30, 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 advised that a disregarded entity or second-level tier should be able to sign a closing agreement as a pass-through partner under section 6224(c)(1), relying on the last sentence of that provision. The brief message responded to an internal question about comparing procedures with a large case.

Ruling snapshot

  • Question: May a disregarded entity or second-level tier sign a closing agreement as a pass-through partner?
  • Outcome: advice given
  • Key authorities: IRC § 6224(c)(1)

Full text (IRS public release)

ID: CCA_2010040108574437 Number: 201017053
Release Date: 4/30/2010
Office: ----------
UILC: 6224.01-01

From: -------------------
Sent: Thursday, April 01, 2010 8:57:51 AM
To: --------------------
Cc: -----------
Subject: RE: Compare procedures to large case

The disregarded entity or second level tier should be able to sign a closing agreement as a pass-thru
partner under section 6224(c)(1)(last sentence).

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