Ezel / IRS Rulings / 1027048
Chief Counsel Advice 1027048 Released July 9, 2010 Advice

CCA 1027048: Advice that there is no separate partnership statute to protect

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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 responds to a question about the assessment limitation period for a TEFRA partnership involving a Roth IRA partner. The response states that there is no partnership statute of limitations to protect in the circumstances discussed. It gives no further factual or legal analysis.

Ruling snapshot

  • Question: Is there a separate partnership assessment statute of limitations that applies to the issue discussed?
  • Outcome: advice given
  • Key authorities: IRC § 6229

Full text (IRS public release)

ID: CCA_2010060409403437 Number: 201027048
Release Date: 7/9/2010
Office: ----------
UILC: 6229.00-00

From: -------------------
Sent: Friday, June 04, 2010 9:40:44 AM
To: ---------------
Cc:
Subject: RE: Roth IRA as a TEFRA Partner-Extension of the Statute ---------

    As I said before, there is no partnership statute. So there is no such statute to protect. Call me
    at --------------------if you want to discuss.

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