Ezel / IRS Rulings / 1207005
Chief Counsel Advice 1207005 Released February 17, 2012 Advice

CCA 1207005: Chief Counsel advised how to designate a new tax matters partner

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This page covers one taxpayer's ruling from 2012, 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 2012
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 resolved one taxpayer's situation on its specific facts, 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 advised a partnership to designate a new tax matters partner, or TMP, on the IRS form used for that purpose. If the partnership did not make a new designation, the TMP would automatically be the remaining general partner with the largest profits interest. If no general partners remained, the IRS could designate a limited partner under the cited Treasury regulation procedures.

Ruling snapshot

  • Question: Who becomes the tax matters partner when a partnership has not made a new designation?
  • Outcome: advice
  • Key authorities: IRC § 6231(a)(7)(B); Treas. Reg. § 301.6231(a)(7)-1(l)(1)(i), (m), and (p)

Full text (IRS public release)

ID: CCA_2012012510512237 Number: 201207005
Release Date: 2/17/2012
Office: ---------
UILC: 6231.07-00

From: --------------------
Sent: Wednesday, January 25, 2012 10:51:38 AM
To: ----------------------
Cc: ----------------------------------------------------------
Subject: RE: TMP

Ask the partnership to designate a new TMP on the IRS form designated for this purpose.

In the absence of a new designation the TMP is automatically the largest profits interest general partner
that remains. I.R.C. 6231(a)(7)(B); Treas. Reg. 301.6231(a)(7)-1(L)(1)(i) and -1(m)

If there are no remaining general partners, the Service may designate a limited partner as TMP under the
procedures set forth in Treas. Reg. 301.6231(a)(7)-1(p).

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