Ezel / IRS Rulings / 201536021

Tax matters partner must have authority to act for entity

Number
201536021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
August 20, 2015
Publicly released
September 4, 2015
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 2015, 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 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 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

This very short email gives affirmative answers to questions that do not appear in the released document. The first answer is conditional: Entity 2's tax matters partner must be a general partner or manager of Entity 2, or otherwise have authority under state law to act for it. The email also gives a second unqualified “yes,” but the corresponding question is not available. No additional facts or analysis appear in the release.

Ruling snapshot

  • Question: The released email does not include the questions presented.
  • Outcome: Advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2015082015402718 [Third Party Communication:

UILC: 6231.07-00
Date of Communication: Month DD, YYYY]

Number: 201536021
Release Date: 9/4/2015
From:
Sent: Thursday, August 20, 2015 3:40:27 PM
To:
Cc:
Bcc:
Subject: RE: Quick Question

Yes, provided that the TMP of Entity 2 is a general partner/manager of Entity 2 (or,
otherwise has authority under state law to act on behalf of Entity 2).

And, yes.

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