Ezel / IRS Rulings / 201040011

CCA 201040011: A state-authorized person should sign for an LLC tax matters partner

Number
201040011
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
September 7, 2010
Publicly released
October 8, 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 stated that, because the tax matters partner was an LLC, a person authorized under state law should sign on behalf of the LLC. It directed the reader to page 10 of Notice CC-2009-027, dated August 21, 2009.

Ruling snapshot

  • Question: Who should sign on behalf of an LLC serving as the tax matters partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6229; Notice CC-2009-027, page 10

Full text (IRS public release)

ID: CCA_2010090709364537 Number: 201040011
Release Date: 10/8/2010
Office: ----------
UILC: 6229.02-00

From: -------------------
Sent: Tuesday, September 07, 2010 9:36:48 AM
To: ----------------------
Cc: ----------------------------------
Subject: RE: trust info

Since the TMP is an LLC, a person authorized under state law should sign on behalf of the LLC. See
page 10 of the attached Notice

CC-2009-027 (August 21, 2009)

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