Ezel / IRS Rulings / 1040009
Chief Counsel Advice 1040009 Released October 8, 2010 Advice

CCA 1040009: Partnership items converted when a receiver was appointed

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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 stated that Treas. Reg. § 301.6231(c)-7(b) provides for conversion of a partner's partnership items when a receiver has been appointed in a receivership proceeding. The conversion occurs on the date the receiver is appointed and applies for the latest taxable year for which the United States can file a claim.

Ruling snapshot

  • Question: When do a partner's partnership items convert after a receiver is appointed?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(c)-7(b)

Full text (IRS public release)

ID: CCA_2010090310491137 Number: 201040009
Release Date: 10/8/2010
Office: ----------
UILC: 6231.14-00

From: -------------------
Sent: Friday, September 03, 2010 10:49:14 AM
To: ------------------
Cc: -----------
Subject: RE: Convert TEFRA Investor

Treas. Reg. 301.6231(c)-7(b) provides that if a receiver has been appointed in a receivership proceeding
the partnership items of the partner convert for the latest taxable year with respect to which the United
States can file a claim. The conversion occurs on the date a receiver is appointed.

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