Ezel / IRS Rulings / 201302034

A tax matters partner remains designated until a termination event

Number
201302034
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
October 24, 2012
Publicly released
January 11, 2013
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 2013, 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 2013
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 stated that a properly designated tax matters partner remains the tax matters partner until a termination event occurs under Treas. Reg. § 301.6231(a)(7)-1(l). Leaving the partnership is not itself a termination event, and the advice noted that no court had invalidated the regulation.

Ruling snapshot

  • Question: Does a tax matters partner remain designated after leaving the partnership?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(7)-1(l)

Full text (IRS public release)

ID: CCA_2012102411134337 Number: 201302034
Release Date: 1/11/2013
Office: ---------
UILC: 6231.07-00

From: --------------------
Sent: Wednesday, October 24, 2012 11:13:58 AM
To: ---------------------
Cc: ----------------------------------------
Subject: RE: Question on TMP qualification

Our position is set forth in the regulations. A properly designated TMP remains the TMP until a
termination event occurs under Treas. Reg. 301.6231(a)(7)-1(L). Leaving the partnership is not a
terminating event. No court has invalidated this regulation.

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