Ezel / IRS Rulings / 1025054
Chief Counsel Advice 1025054 Released June 25, 2010 Advice

IRS explained when it may issue an FPAA 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 IRC § 6223(c)(3) permits it to issue an FPAA to an indirect partner identified under Treas. Reg. § 301.6223(c)-1. It explained that a subsection of that regulation allows the Service, at its discretion, to search for and update the relevant information. The Service Center issuing the FPAA is not required to search for information that was not specifically provided under the regulation's other provisions.

Ruling snapshot

  • Question: Must the Service Center search for undisclosed information before issuing an FPAA to an indirect partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6223(c)(3); Treas. Reg. § 301.6223(c)-1(f).

Full text (IRS public release)

ID: CCA_2010052410035537 Number: 201025054
Release Date: 6/25/2010
Office: ----------
UILC: 6223.02-00

From: --------------------
Sent: Monday, May 24, 2010 10:04:02 AM
To: -------------------
Cc: ----------------------------------
Subject: RE: Advice

Section 6223(c)(3) allows us to issue FPAA's to indirect partners who have been identified in accordance
with Treas. Reg. 301.6223(c)-1. Subsection -1(f) of the regulation in question allows the Service, at its
discretion, to search for and update this information on its own - but the Service Center issuing the FPAA
is not required to search for information that is not specifically provided in accordance with the other
provisions of the regulations.

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