Ezel / IRS Rulings / 201721013

Companion advice refers readers to related TAM for substantive analysis

Number
201721013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partner's Distributive Share
Topics
Partnerships
Code sections
§ 704
Ruling dated
February 23, 2017
Publicly released
May 26, 2017
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 2017, 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 2017
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 Chief Counsel Advice accompanied a separately identified Technical Advice Memorandum concerning a partner's distributive share. It directs readers to that memorandum for the facts, issues, law, analysis, and conclusions. The released CCA contains no independent substantive tax analysis or conclusion.

Ruling snapshot

  • Question: What additional advice does the companion CCA provide concerning the section 704 matter?
  • Outcome: Advice given by reference. The CCA points to the related TAM for all substantive discussion.
  • Key authorities: IRC § 704

Full text (IRS public release)

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 201721013
Release Date: 5/26/2017
CC:PSI:03:ARCarmody
Third Party Communication: None
PRENO-106365-17
Date of Communication: Not Applicable

UILC: 704.00-00

date: February 23, 2017
to: William G. Merkle, Area Counsel (Retailers, Food, Pharmaceuticals & Healthcare) (Large Business & International)

from: Richard T. Probst
Senior Technician Reviewer, Branch 3
(Passthroughs & Special Industries)

subject: TAM-136522-15

This Chief Counsel Advice (CCA) responds to your request for assistance. This advice may not be used or cited as precedent.

This CCA accompanies TAM-136522-15. Please see that document for a full recitation of facts, issues, law, analysis, and conclusions.

CASE DEVELOPMENT, HAZARDS AND OTHER CONSIDERATIONS
PRENO-106365-17
2

This writing may contain privileged information. Any unauthorized disclosure of this
writing may undermine our ability to protect the privileged information. If disclosure is
determined to be necessary, please contact this office for our views.

Please call 202-317-5279 if you have any further questions.

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