Ezel / IRS Rulings / 201210030

CCA 201210030: Partnership information for notice purposes

Number
201210030
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Information for Secretary's Notices
Topics
Procedure, penalties, and administration
Code sections
§ 6223
Ruling dated
August 4, 2011
Publicly released
March 9, 2012
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 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 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 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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