Ezel / IRS Rulings / 201251013

CCA 201251013: CCA addresses designation of an indirect partner as tax matters partner

Number
201251013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
October 2, 2012
Publicly released
December 21, 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 an indirect partner may be designated as a partnership's tax matters partner. The advice states that the Service may designate an indirect partner as tax matters partner under the flush language following IRC section 6231(a)(7)(B), together with section 6231(a)(2)(B). The short advice concerns the authority to make that designation.

Ruling snapshot

  • Question: May the Service designate an indirect partner as the tax matters partner?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6231(a)(2)(B) and 6231(a)(7)(B)

Full text (IRS public release)

ID: CCA_2012100210291537 Number: 201251013
Release Date: 12/21/2012
Office: ----------
UILC: 6231.07-00

From: -------------------
Sent: Tuesday, October 02, 2012 10:29:29 AM
To: -------------------
Cc: -----------
Subject: RE: T.R. 301.6231(a)(7)-2

An indirect partner can be designated as TMP by the Service under the flush language after section
6231(a)(7)(B) and section 6231(a)(2)(B).

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