Ezel / IRS Rulings / 201149028

Assessment period for unidentified indirect TEFRA partners

Number
201149028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Unidentified Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
December 2, 2011
Publicly released
December 9, 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 whether the assessment period remained open for unidentified indirect partners after a timely TEFRA proceeding. It stated that, under section 6229(e), the statute remains open until one year after the partner's identifying information is furnished to the Service. The advice concluded that the Service might still be able to assess the unidentified indirect partners.

Ruling snapshot

  • Question: How long does the assessment period remain open for unidentified indirect partners after a timely TEFRA proceeding?
  • Outcome: advice given
  • Key authorities: IRC § 6229(e).

Full text (IRS public release)

ID: CCA_2011120209500137 Number: 201149028
Release Date: 12/9/2011
Office: ----------
UILC: 6229.05-00

From: -------------------
Sent: Friday, December 02, 2011 9:50:20 AM
To: ---------------------
Cc: ---------------------------------------------------------------------------
Subject: RE: Potential Underassessed TEFRA Investor

Since we completed a timely TEFRA proceeding, under section 6229(e) the statute is held open for
unidentified indirect partners up until one year after their identifying information is furnished to the
Service. Thus we may still be able to assess the unidentified indirect partners. -----------------------------------
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