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Chief Counsel Advice 1221019 Released May 25, 2012 Advice

CCA 1221019: Chief Counsel addresses TEFRA treatment of a one-partner entity

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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 addressed whether the TEFRA partnership rules applied to a redacted entity. The advice said TEFRA applied for one year because the entity had a flow-through entity as a partner. For a later period, the advice concluded that TEFRA did not apply because the entity was no longer a partnership and, with only one partner, was a disregarded entity. The advice cited Treas. Reg. § 301.6231(a)(1)-1(a)(2).

Ruling snapshot

  • Question: Did TEFRA apply to the entity for the identified periods?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(1)-1(a)(2)

Full text (IRS public release)

ID: CCA_2012050408160337 Number: 201221019
Release Date: 5/25/2012
Office: ---------
UILC: 6231.01-01

From: --------------------
Sent: Friday, May 04, 2012 8:16:20 AM
To: ----------------
Cc: ------------
Subject: RE: TEFRA Question

For the year ending ------- TEFRA would apply to X. because it has a flow through entity as a partner.
Treas. Reg. 301.6231(a)(1)-1(a)(2).

For ------- X would not be subject to TEFRA because it is no longer a partnership. With only one "partner"
it would be a disregarded entity.

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