Ezel / IRS Rulings / 201018011

CCA 201018011: Chief Counsel advised to await the TEFRA proceeding

Number
201018011
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partnership Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
April 13, 2010
Publicly released
May 7, 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 issues characterized as partnership items subject to an FPAA. The advice stated that the IRS should not issue a notice of deficiency until the TEFRA proceeding was over. The memorandum provides no additional factual analysis.

Ruling snapshot

  • Question: Should the IRS issue a notice of deficiency before a TEFRA proceeding concerning partnership items is complete?
  • Outcome: Advice given
  • Key authorities: IRC § 6231.

Full text (IRS public release)

ID: CCA_2010041316473937 Number: 201018011
Release Date: 5/7/2010
Office: ----------
UILC: 6231.03-00

From: -------------------
Sent: Tuesday, April 13, 2010 4:47:42 PM
To: -----------------
Cc: -----------
Subject: RE: TEFRA Question

The issues are all partnership items subject to an FPAA. We should not issue a notice of deficiency until
the TEFRA proceeding is over.

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