Ezel / IRS Rulings / 201652019
Chief Counsel Advice 201652019 Released December 23, 2016 Advice

Tax matters partner must sign earlier-year extensions

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This page covers one taxpayer's ruling from 2016, 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 2016
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 addressed who may sign Form 921-P for earlier partnership tax years. If the named person is the tax matters partner for those years, she may sign. Otherwise, the earlier years' tax matters partner must sign unless the partnership gives her written authority to sign the consent.

Ruling snapshot

  • Question: Who may sign Form 921-P to extend the period for earlier partnership tax years?
  • Outcome: advice given
  • Key authorities: IRC § 6231; Form 921-P instructions

Full text (IRS public release)

ID: CCA_2016100612570315
UILC: 6231.07-00

Number: 201652019
Release Date: 12/23/2016
From:
Sent: Thursday, October 06, 2016 12:57:03 PM
To:
Cc:
Bcc:
Subject: RE TEFRA Statute Extension for Rev. Proc. 92-29 Project Questions

John,

If, in your example, Jane Smith is now the TMP for the earlier tax years, she may sign
the Form 921-P for those years. If she is not, then the TMP for the earlier years will
need to sign Forms 921-P unless the partnership provides written authorization for Jane
Smith to sign a consent for those years. See the instructions on the reverse side of the
Form 921-P.

Samuel Berman
Special Counsel
Office of Division Counsel
(Small Business/Self-Employed)

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