Ezel / IRS Rulings / 201515033
Chief Counsel Advice 201515033 Released April 10, 2015 Advice

Tax matters partner may bind certain small direct partners

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
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 resolved one taxpayer's situation on its specific facts, 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 advised that a tax matters partner may bind non-notice partners to a settlement under former section 6224(c)(3). A non-notice partner for this purpose is a direct partner holding less than a one percent interest in a partnership with more than 100 partners. The advice identifies sections 6223 and 6231 and the section 301.6224(c)-1 regulations as the governing authorities.

Ruling snapshot

  • Question: May a tax matters partner bind non-notice partners to a TEFRA settlement?
  • Outcome: Advice given: yes, under section 6224(c)(3).
  • Key authorities: IRC §§ 6223(b), 6224(c)(3), and 6231(a)(8); Treas. Reg. § 301.6224(c)-1.

Full text (IRS public release)

ID: CCA_2015031013474801 [Third Party Communication:

UILC: 6224.01-05 Date of Communication: Month DD, YYYY]

Number: 201515033
Release Date: 4/10/2015
From:
Sent: Tuesday, March 10, 2015 1:47:48 PM
To:
Cc:
Bcc:
Subject: RE: TEFRA Closing Agreement question

The TMP can bind non-notice partners to a settlement under section 6224(c)(3). For
this purpose, non-notice partner is defined as a direct partner with less than a one
percent interest in a partnership with more than 100 partners. I.R.C. 6231(a)(8); 6223(b)
and Treas. Reg. 301.6224(c)-1(a) and (b).

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