CCA 1310036: How to identify a consolidated group on Form 870-PT

Plain-English summary

Chief Counsel addressed how a taxpayer's name should appear on Form 870-PT for a consolidated group. The form generally should use the name shown on the consolidated return, such as the common parent followed by “and Subsidiaries.” If the consolidated return lists only the common parent, the form should use that name with an asterisk and a note identifying the consolidated group and tax year.

Ruling snapshot

• Question: How should a consolidated group be identified in the caption block of Form 870-PT?
• Outcome: Advice given, use the consolidated-return name and add the specified group note when needed.
• Key authorities: IRC §§ 6224 and 7121

Full text (IRS public release)

ID: CCA_2012052916092120 Number: 201310036
Release Date: 3/8/2013
Office: ----------------------
UILC: 6224.00-00, 7121.00-00

From: ----------------------
Sent: Tuesday, May 29, 2012 4:09:32 PM
To: ------------------------------------------
Cc:
Subject: RE: Form 870-PT

Generally, you would use the name as Taxpayer has written (typed) it on the consolidated return.
Generally, it will be listed as "Corporation X and Subsidiaries" (Corporation X being the common parent of
the consolidated group).

If the Taxpayer's name is listed on the consolidated return only as "Corporation X" then type in the caption
block on the Form 870-PT "Corporation X" and put an asterisk right next to it. At the bottom of the form, type
"*This is with regard to the consolidated tax liability of the Corporation X and Subsidiaries
consolidated group for tax year ____."