Chief Counsel Advice 201916005 Released April 19, 2019 Advice

Transmittal email forwarding a CCA memo on SECA loss limitations for a general partner

Apply this to your situation

This page covers one taxpayer's ruling from 2019, 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 2019
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 is a short transmittal email forwarding a separate Chief Counsel Advice memorandum. The email explains that the attached CCA memo, based on the offices' earlier discussions and a general fact pattern, addresses whether the loss limitations apply in determining a general partner's self-employment (SECA) tax, and it notes that a redacted version will be published as necessary to protect privileged or confidential information. The email itself contains no legal analysis; it simply describes the subject of the attached memorandum (the interaction between the loss limitation rules, such as the at-risk rules of section 465, and the computation of net earnings from self-employment under section 1402 for a general partner).

Ruling snapshot

  • Question: (Transmittal) forwarding a CCA memo on whether the loss limitations apply in determining a general partner's self-employment tax.
  • Outcome: advice (cover email; the substantive analysis is in the attached memorandum)
  • Key authorities: IRC §§ 1402 (net earnings from self-employment), 465 (at-risk loss limitation)

Full text (IRS public release)

ID:        CCA_2019030415405751
UILC:      1402.01-00, 465.00-00

Number: 201916005
Release Date: 4/19/2019
From:
Sent: Monday, March 04, 2019 3:40:57 PM
To:
Cc:
Bcc:
Subject: SECA-loss limitations

Hi,

Attached is a CCA memo based on our earlier discussions, including about a general
fact pattern, on the issue of whether the loss limitations apply in determining a general
partner’s self-employment tax. We will publish a redacted version (as necessary for any
privileged or confidential information).

If you have any questions or concerns, feel free to contact us.

Thank you,

---------------------------
------------------------------------------------------------
---------------------------------

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2019, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.