Ezel / IRS Rulings / 201101018

CCA 201101018: A state-law authorized official must sign for the entity

Number
201101018
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
November 1, 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 addressed a signature question involving a tax matters partner and Form 872-P. It directs the reader to page 10 of the attached Notice on Frequently Asked TEFRA Questions. The advice states that a tax matters partner has no authority to sign a document on behalf of a state-law entity, so the current state-law authorized official should sign for the entity instead of its own tax matters partner.

Ruling snapshot

  • Question: Who may sign a document for a state-law entity that is a tax matters partner?
  • Outcome: Advice given
  • Key authorities: IRC § 6229; Form 872-P; Notice on Frequently Asked TEFRA Questions

Full text (IRS public release)

ID: CCA_2010110110203937 Number: 201101018
Release Date: 1/7/2011
Office: ----------
UILC: 6229.02-00

From: --------------------
Sent: Monday, November 01, 2010 10:20:41 AM
To: -------------
Cc: ------------
Subject: RE: TEFRA Question re 872-P

Your question is addressed on page 10 in the attached Notice on Frequently Asked TEFRA Questions.
The TMP has no authority to sign any document on behalf of a state law entity so we should be looking to
the current state law authorized official to sign on behalf of your TMP that is a state law entity - not its own
TMP.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace