Ezel / IRS Rulings / 201027050

CCA 201027050: Advice that two cases treat the issue as a nonpartnership item

Number
201027050
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
June 7, 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 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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