Ezel / IRS Rulings / 201221019

CCA 201221019: Chief Counsel addresses TEFRA treatment of a one-partner entity

Number
201221019
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Exception for Small Partnerships
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
May 4, 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 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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