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Chief Counsel Advice 1042030 Released October 22, 2010 Advice

CCA 1042030: An authorized representative may sign Form 872-P for a TMP

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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 addressed who may sign Form 872-P for a TEFRA partnership's tax matters partner. It stated that a power of attorney for the TMP may sign the form, although the IRS prefers that the TMP sign legally significant documents personally. The advice also noted that the regulations permit the authority to be granted through a document signed by all general partners.

Ruling snapshot

  • Question: Who may sign Form 872-P for a TEFRA partnership's tax matters partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6229; regulations governing authority for TEFRA partnership documents

Full text (IRS public release)

ID: CCA_2010082315203237 Number: 201042030
Release Date: 10/22/2010
Office: ----------
UILC: 6229.02-00

From: -------------------
Sent: Monday, August 23, 2010 3:20:34 PM
To: -----------------------
Cc: ---------------------------------------------------------------------------------------
Subject: RE: Form 872-P Signature (TEFRA)

A POA for TMP can sign the Form 872-P, but we much prefer the TMP himself to sign legally significant
documents.
Otherwise the regulations provide that the authority may be granted through a document signed by all of
the general partners.

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