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Chief Counsel Advice 1236027 Released September 7, 2012 Advice

CCA 1236027: Advice addresses a statute extension consent after entity-status change

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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 a consent extending the statute of limitations for a TEFRA partnership after a change in entity status. It states that the change does not affect the procedures because a TEFRA proceeding is analogous to a class action for the partners and the entity is generally not a party. The advice concludes that the TMP should sign the consent for the partners for the relevant year. The partnership name on the consent should match the name shown on that year's partnership return.

Ruling snapshot

  • Question: Who should sign a statute-extension consent after a TEFRA partnership's entity status changes?
  • Outcome: Advice
  • Key authorities: IRC § 6229; TEFRA partnership procedures

Full text (IRS public release)

ID: CCA_2012062214342937 Number: 201236027
Release Date: 9/7/2012
Office: ----------
UILC: 6229.02-00

From: --------------------
Sent: Friday, June 22, 2012 2:34:47 PM
To: ----------------
Cc: ----------------------------------
Subject: RE: Statute extension consent for a TEFRA partnership

The change in entity status has no effect on the procedures since a TEFRA proceeding is analogous to a
class action proceeding for the partners in which the entity itself is generally not a party. So the consent
would be signed by the TMP for the partners for the year in issue with the partnership name being the
same as reflected on the partnership return for that year. You can call me anytime at the above number.

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