Ezel / IRS Rulings / 201042033

CCA 201042033: Section 6501(c)(10) applies to non-disclosing TEFRA partners

Number
201042033
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Assessment and Collection (Barred v. Not Barred)
Topics
Procedure, penalties, and administration
Code sections
§ 6501
Ruling dated
September 30, 2010
Publicly released
October 22, 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 the application of IRC § 6501(c)(10) to partners in a TEFRA partnership. It stated that the provision applies to partners who fail to disclose their participation in a listed transaction. The short advice does not provide additional facts or analysis beyond that conclusion.

Ruling snapshot

  • Question: Does IRC § 6501(c)(10) apply to partners in a TEFRA partnership who fail to disclose a listed transaction?
  • Outcome: Advice given
  • Key authorities: IRC § 6501(c)(10)

Full text (IRS public release)

ID: CCA_2010093015562337 Number: 201042033
Release Date: 10/22/2010
Office: ----------
UILC: 6501.00-00

From: -------------------
Sent: Thursday, September 30, 2010 3:56:25 PM
To: ---------------
Cc: ------------------------------------------------------
Subject: RE: Section 6501(c)(10) and TEFRA partnerships

Section 6501(c)(10) applies to partners in a TEFRA partnership who fail to disclose their listed transaction.

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