Ezel / IRS Rulings / 201119030

CCA 201119030: TEFRA notice goes to every partner on Schedule K-1

Number
201119030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice to Partners of Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6223
Ruling dated
April 12, 2011
Publicly released
May 13, 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 confirmed that IRC § 6223(a)(1) requires issuance of a Notice of Beginning of Administrative Proceeding for the TEFRA matter described in the request. Under § 6223(c)(1), the notice should be sent to every partner listed on the Schedules K-1.

Ruling snapshot

  • Question: To whom should the Notice of Beginning of Administrative Proceeding be sent?
  • Outcome: Advice given
  • Key authorities: IRC § 6223(a)(1) and (c)(1).

Full text (IRS public release)

ID: CCA_2011041210015837 Number: 201119030
Release Date: 5/13/2011
Office: ---------
UILC: 6223.00-00

From: --------------------
Sent: Tuesday, April 12, 2011 10:02:09 AM
To: ---------------
Cc: ---------------------------------
Subject: RE: Quick TEFRA question

You are correct that section 6223(a)(1) requires issuance of a Notice of Beginning of Administrative
Proceeding. Under section 6223(c)(1) this notice should be sent to every partner listed on the Schedules
K-1.

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