Ezel / IRS Rulings / 1025052
Chief Counsel Advice 1025052 Released June 25, 2010 Advice

IRS advised that TEFRA adjustments may be disclosed to an indirect partner

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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

The IRS advised that TEFRA adjustments may be disclosed to an indirect partner under IRC § 6103(h)(4)(A). It also cited Abelein v. U.S. from the Ninth Circuit as supporting authority. The short memo does not identify the taxpayer or describe the underlying adjustments.

Ruling snapshot

  • Question: May TEFRA adjustments be disclosed to an indirect partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(4)(A); Abelein v. U.S. (9th Circuit).

Full text (IRS public release)

ID: CCA_2010052008290937 Number: 201025052
Release Date: 6/25/2010
Office: --------
UILC: 6103.10-03

From: --------------------
Sent: Thursday, May 20, 2010 8:29:15 AM
To: --------------
Cc: ---------------------------------
Subject: RE: Brief Status update

You may disclose the TEFRA adjustments to an indirect partner under section 6103(h)(4)(A) and Abelein
v. U.S. (9th Circuit).

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