Ezel / IRS Rulings / 1022017
Chief Counsel Advice 1022017 Released June 4, 2010 Advice

CCA 1022017: The parent may sign for the entire consolidated group

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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 the parent may sign for the entire consolidated group in the matter described in the email. The advice cites Treas. Reg. § 1.1502-77A and includes redacted details about the subsidiaries and the specific filing. The short CCA addresses who may sign on behalf of the consolidated group.

Ruling snapshot

  • Question: May the parent sign for the entire consolidated group?
  • Outcome: Advice given
  • Key authorities: Treas. Reg. § 1.1502-77A

Full text (IRS public release)

ID: CCA_2010042813324237 Number: 201022017
Release Date: 6/4/2010
Office: ----------
UILC: 1502.77-00

From: -------------------
Sent: Wednesday, April 28, 2010 1:32:48 PM
To: --------------------
Cc: ------------------------------------
Subject: RE: 872-F for subs years -------------

The parent can sign for the entire consolidated group, --------------------------------------------------------------------
----------------------------------------. Treas. Reg. 1.1502-77A.

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