Ezel / IRS Rulings / 1210030
Chief Counsel Advice 1210030 Released March 9, 2012 Advice

CCA 1210030: Partnership information for notice purposes

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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 advice addresses the information used to give notices related to a partnership. It states that IRC § 6223(c) requires the Service to use information from the partnership return for notice purposes. The advice concludes that the Service was in compliance if it used that information and also issued a generic notice to the tax matters partner under the cited Treasury regulation.

Ruling snapshot

  • Question: May the Service use partnership-return information and issue a generic tax matters partner notice for notice purposes?
  • Outcome: Advice given.
  • Key authorities: IRC § 6223(c); Treas. Reg. § 301.6223(a)(1)-1.

Full text (IRS public release)

ID: CCA_2011080414592137 Number: 201210030
Release Date: 3/9/2012
Office: ----------
UILC: 6223.02-00

From: --------------------
Sent: Thursday, August 04, 2011 2:59:26 PM
To: --------------------
Cc: ------------------------------------
Subject: RE: FPAA

Section 6223(c) says we are to use the information of the partnership return for notice purposes. As long
as we did that, an also issued a generic TMP notice in accordance with Treas. Reg. 301.6223(a)(1)-1, we
are fine.

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