Ezel / IRS Rulings / 201721013
Chief Counsel Advice 201721013 Released May 26, 2017 Advice

Companion advice refers readers to related TAM for substantive analysis

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This page covers one taxpayer's ruling from 2017, 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 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 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

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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