Ezel / IRS Rulings / 201027048

CCA 201027048: Advice that there is no separate partnership statute to protect

Number
201027048
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Period of Limitations for Making Assessments
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
June 4, 2010
Publicly released
July 9, 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 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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