Ezel / IRS Rulings / 201319025

A TMP can bind small-interest partners in a large partnership

Number
201319025
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Canada
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
March 14, 2013
Publicly released
May 10, 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 addresses whether a tax matters partner, or TMP, can bind partners holding less than a one-percent interest in a large partnership. The advice states that the TMP can bind those partners when the partnership has more than 100 partners. The memo provides no further factual details.

Ruling snapshot

  • Question: Can a TMP bind partners with less than a one-percent interest in a partnership with more than 100 partners?
  • Outcome: Advice given.
  • Key authorities: IRC § 6224.

Full text (IRS public release)

ID: CCA_2013031410393701 Number: 201319025
Release Date: 5/10/2013
UILC: 6224.01-05

From: -------------------
Sent: Thursday, March 14, 2013 10:39:37 AM
To: -------------------
Cc:
Bcc:
Subject: RE: Closing agreements

The TMP can bind partners with less than a one percent interest in a partnership with
more than 100 partners.

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