Ezel / IRS Rulings / 1235020
Chief Counsel Advice 1235020 Released August 31, 2012 Advice

IRS advice on the assessment period for non-filing indirect partners

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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 statute of limitations for non-filing indirect partners in a partnership. The advice states that the limitations period remains open indefinitely under section 6501(c)(3). It explains that section 6229 does not shorten a partner's section 6501 period for partnership items, but instead provides a minimum period during which no partner's section 6501 period can expire.

Ruling snapshot

  • Question: Does section 6229 shorten a partner's section 6501 assessment period for partnership items?
  • Outcome: Advice given, section 6229 provides a minimum period and does not shorten the section 6501 period.
  • Key authorities: IRC §§ 6501(c)(3) and 6229

Full text (IRS public release)

ID: CCA_2012062012002937 Number: 201235020
Release Date: 8/31/2012
Office: ----------
UILC: 6501.00-00

From: -------------------
Sent: Wednesday, June 20, 2012 12:00:46 PM
To: --------------------
Cc: ---------------------------
Subject: RE: TEFRA Question

The statute is open indefinitely for the non-filing indirect partners. I.R.C. 6501(c)(3). Three circuit courts
of appeal and an en banc opinion of the Tax Court have held that section 6229 does not shorten a
partner's section 6501 statute with respect to partnership items. Section 6229 merely provides a minimum
period during which no partner's section 6501 statute can expire with respect to partnership items.

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