Ezel / IRS Rulings / 201101014

CCA 201101014: Advice on signing for a layered partnership structure

Number
201101014
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
October 7, 2010
Publicly released
January 7, 2011
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 2011, 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 2011
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 answered a question about how to identify the signatory for a document in a layered entity structure. It approved a signature block that identifies the individual as a general partner of one partnership, acting through successive manager roles, and ultimately as the tax matters partner of the TEFRA entity. The document gives the signature format without further explanation of the underlying facts.

Ruling snapshot

  • Question: How should the signature block identify an individual signing through several partnership and manager roles for a TEFRA entity?
  • Outcome: Advice given
  • Key authorities: IRC § 6229

Full text (IRS public release)

ID: CCA_2010100710571937 Number: 201101014
Release Date: 1/7/2011
Office: ----------
UILC: 6229.02-00

From: --------------------
Sent: Thursday, October 07, 2010 10:57:24 AM
To: ---------------------
Cc: ------------
Subject: RE: 6229(b) question

Yes. The signature block would be John Doe as general partner of ABC partnership as manager of ABC
LLC(DRE) as manager of XYZ LLC(DRE) as TMP of TEFRA entity.

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