Ezel / IRS Rulings / 201116020

CCA 201116020: IRS discussed settlement agreements by pass-through partners

Number
201116020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Settlement Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
March 22, 2011
Publicly released
April 22, 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 settlement agreement made by a pass-through partner in a tiered partnership structure. It stated that a settlement agreement by a pass-through partner binds that partner's partners under IRC § 6224(c)(1). Each tier therefore needs to enter into the closing agreement under the facts described in the memorandum.

Ruling snapshot

  • Question: Who must enter a closing agreement when a pass-through partner settles a TEFRA matter?
  • Outcome: Advice given
  • Key authorities: IRC § 6224(c)(1)

Full text (IRS public release)

ID: CCA_2011032209060537 Number: 201116020
Release Date: 4/22/2011
Office: ----------
UILC: 6224.01-01

From: -------------------
Sent: Tuesday, March 22, 2011 9:06:10 AM
To: --------------------
Cc: -----------
Subject: RE: TEFRA partnership question

A settlement agreement by a pass-thru partner (i.e., a tier) binds the tier's partners. I.R.C. 6224(c)(1), last
sentence. So each tier will need to enter into the closing agreement under your facts.

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