Ezel / IRS Rulings / 1033035
Chief Counsel Advice 1033035 Released August 20, 2010 Advice

CCA 1033035: Several forms could keep the partnership-item statute open

Apply this to your situation

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 addressed how the statute for assessing partnership items against a partner could remain open. It noted that the revised Form 872 had replaced Form 872-i, but said the statute could be open through Form 872-i, the current Form 872 revision, or indefinitely when a redacted partner had not filed a United States return. The memorandum provides a short procedural conclusion and does not identify the partner or the tax years involved.

Ruling snapshot

  • Question: What circumstances could leave the statute open for assessing partnership items against a partner?
  • Outcome: advice given
  • Key authorities: IRC § 6229; Forms 872 and 872-i

Full text (IRS public release)

ID: CCA_2010070713452537 Number: 201033035
Release Date: 8/20/2010
Office: ----------
UILC: 6229.02-00

From: -------------------
Sent: Wednesday, July 07, 2010 1:45:28 PM
To: --------------------------------------------------------------------------------------------
Cc: -------------------------------------------------
Subject: RE:

Note that the new Form 872 (rev. Sept. 2009) has now replaced the Form 872-i. So the statute for
assessing partnership items against a partner can be open via a Form 872-i, the current revision of the
Form 872, or because the --- partner did not file a U.S. return so that his statute is open indefinitely.

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2010, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.