Ezel / IRS Rulings / 201113027

CCA 201113027: Dissolution terminates a tax matters partner's status

Number
201113027
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
February 23, 2011
Publicly released
April 1, 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 the effect of a tax matters partner's dissolution. It stated that under Treas. Reg. § 301.6231(a)(7)-1(l)(iii), the dissolution terminated the entity's status as tax matters partner for the redacted tax year.

Ruling snapshot

  • Question: Does a tax matters partner's dissolution terminate its status for the tax year?
  • Outcome: Advice given, the dissolution terminated the TMP status for the stated year.
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(7)-1(l)(iii).

Full text (IRS public release)

ID: CCA_2011022310344637 Number: 201113027
Release Date: 4/1/2011
Office: ----------
UILC: 6231.07-00

From: -------------------
Sent: Wednesday, February 23, 2011 10:34:51 AM
To: -----------------------
Cc: -----------
Subject: RE: Quick question

Under Treas. Reg. 301.6231(a)(7)-1(l)(iii) the dissolution of the TMP terminated its status as TMP for the -
------- tax year.

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