Ezel / IRS Rulings / 201103051

CCA 201103051: Counsel addresses a tier partner's Form 872-P limitations extension

Number
201103051
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
December 21, 2010
Publicly released
January 21, 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 advised that a tier partner's Form 872-P should extend the limitations period for items flowing from source partnership items under IRC § 6229(b)(3). The advice states that the consent need only specify that it applies to “tax attributable to partnership items,” and that the preprinted Form 872-P language satisfies that requirement.

Ruling snapshot

  • Question: Does a tier partner's Form 872-P extend the limitations period for items flowing from source partnership items?
  • Outcome: Advice given
  • Key authorities: IRC § 6229(b)(3); Form 872-P

Full text (IRS public release)

ID: CCA_2010122112074537 Number: 201103051
Release Date: 1/21/2011
Office: ----------
UILC: 6229.02-00

From: -------------------
Sent: Tuesday, December 21, 2010 12:07:48 PM
To: --------------------
Cc: ----------------------------------------------------
Subject: RE: Specialist referral-AAR

A Form 872-P of a tier partner should extend the statute for items flowing from source partnership items
under section 6229(b)(3) which only requires that the consent specifically state that it applies to "tax
attributable to partnership items." The preprinted language of the Form 872-P meets this requirement.

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