Ezel / IRS Rulings / 201221015

CCA 201221015: Chief Counsel says a disregarded entity is not a partnership partner

Number
201221015
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partnerships v. Associations
Topics
Entity classification
Code sections
§ 7701
Ruling dated
March 7, 2012
Publicly released
May 25, 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 addressed whether a partnership existed for federal tax purposes. The advice concluded that a redacted entity was disregarded as separate from its owner and therefore was not considered a partner. Because there was only one owner for federal tax purposes, the advice concluded that there was no partnership. The advice applied the entity-classification rule in IRC § 7701.

Ruling snapshot

  • Question: Did the identified entities constitute a partnership for federal tax purposes?
  • Outcome: Advice given
  • Key authorities: IRC § 7701

Full text (IRS public release)

ID: CCA_2012030712424338 Number: 201221015
Release Date: 5/25/2012
Office: ----------
UILC: 7701.02-00

From: ----------------
Sent: Wednesday, March 07, 2012 12:43:18 PM
To: -------------------
Cc:
Subject: RE: Advice requested; short statute

-------

Your instincts are correct. There is no partnership. ----- is disregarded as separate
from ---- and thus isn't considered a partner for federal tax purposes. The only owner
for federal tax purposes is ----. One owner, no partnership.

Let me know if you need anything else.

------------

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