Ezel / IRS Rulings / 201036017

CCA 201036017: A grantor trust partner causes TEFRA procedures to apply

Number
201036017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Exception for Small Partnerships
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
June 24, 2010
Publicly released
September 10, 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 addressed whether TEFRA partnership procedures applied when a grantor trust or another disregarded entity was a partner. The advice concludes that the presence of that partner makes TEFRA apply and cites Revenue Ruling 2004-88 and Primco v. Commissioner. The released text provides no further factual explanation.

Ruling snapshot

  • Question: Do TEFRA procedures apply when a grantor trust or disregarded entity is a partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Rev. Rul. 2004-88

Full text (IRS public release)

ID: CCA_2010062413485337 Number: 201036017
Release Date: 9/10/2010
Office: ----------
UILC: 6231.01-01

From: -------------------
Sent: Thursday, June 24, 2010 1:48:57 PM
To: --------------------
Cc: -----------
Subject: RE: TEFRA QUESTION

A grantor trust or other disregarded entity as a partner makes TEFRA apply. Rev. Rul. 2004-88; Primco
v. Commissioner.

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