Ezel / IRS Rulings / 1027050
Chief Counsel Advice 1027050 Released July 9, 2010 Advice

CCA 1027050: Advice that two cases treat the issue as a nonpartnership item

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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 identifies two cases that classify the issue under discussion as a nonpartnership item in a TEFRA context. The brief response cites Hang v. Commissioner and Alpha Sands. It does not provide further analysis or resolve a specific taxpayer's case.

Ruling snapshot

  • Question: Do two cited cases treat the issue as a nonpartnership item?
  • Outcome: advice given
  • Key authorities: IRC § 6231; Hang v. Commissioner; Alpha Sands

Full text (IRS public release)

ID: CCA_2010060714050837 Number: 201027050
Release Date: 7/9/2010
Office: ----------
UILC: 6231.02-00

From: -------------------
Sent: Monday, June 07, 2010 2:05:13 PM
To: --------------------------------------------
Cc: ---------------------------------
Subject: RE: FPAA question

Two cases hold that it a nonpartnership item as well. Hang v. Commissioner (Tax Court) and Alpha
Sands (Claims Court). -------------------------------------------------------------------------------------------------------------

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