Ezel / IRS Rulings / 201402014

Dissolution of a designated tax matters partner

Number
201402014
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Publicly released
January 10, 2014
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 2014, 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 2014
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

The Chief Counsel advice addresses what happens to Tax Matters Partner status when the designated partner dissolves. It states that dissolution terminates the partner's status and designation. Because both direct partners dissolved, the advice states that an indirect partner may be designated as the Tax Matters Partner under the cited regulation.

Ruling snapshot

  • Question: Can an indirect partner be designated as Tax Matters Partner after the designated and direct partners dissolve?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Treas. Reg. § 301.6231(a)(7)-1(n), (p)

Full text (IRS public release)

ID: CCA_2013121109585001 Third Party Communication: None

UILC: 6231.07-00
Date of Communication: Not Applicable

Number: 201402014
Release Date: 1/10/2014
From:
Sent: Wednesday, December 11, 2013 9:58:50 AM
To:
Cc:
Bcc:
Subject: RE: Statute extension

Dissolution of the TMP terminates TMP status. So if the designated TMP dissolved, its designation
terminated. Since both direct partners dissolved, we can designate an indirect partner as TMP under
Treas. Reg. 301.6231(a)(7)-1(n) and (p).

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