Ezel / IRS Rulings / 201147028

CCA 201147028: A tax matters partner's authorized representative may sign statute extensions

Number
201147028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 6501
Ruling dated
November 16, 2011
Publicly released
November 25, 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 addresses whether a tax matters partner's power of attorney may sign an extension of the assessment statute for the tax matters partner. The advice says the authorized representative may sign for the tax matters partner, assuming the representative's Form 2848 does not restrict that authority.

Ruling snapshot

  • Question: May a tax matters partner's authorized representative sign a statute extension for the tax matters partner?
  • Outcome: Advice given, subject to any restriction in Form 2848.
  • Key authorities: IRC §§ 6223 and 6501; Form 2848.

Full text (IRS public release)

ID: CCA_2011111608455837 Number: 201147028
Release Date: 11/25/2011
Office: ----------
UILC: 6223.05-00

From: -------------------
Sent: Wednesday, November 16, 2011 8:46:04 AM
To: --------------------------
Cc: ------------------------------------
Subject: RE: TEFRA LLC question

A TMP’s POA can sign statute extensions for a TMP (assuming no restriction in the Form 2848). -----------
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