Chief Counsel Advice 202208015 Released February 25, 2022 Advice

Adding the title "Member" next to a signature on Form 8979 does not invalidate a Partnership Representative appointment

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This page covers one taxpayer's ruling from 2022, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

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

Under the centralized partnership audit rules (the BBA regime), a partnership designates a Partnership Representative (PR) to act for it before the IRS, using Form 8979. Someone asked Chief Counsel whether writing a title such as "Member" next to a person's name on the signature line of that form would call the appointment into question. In this brief email advice, Counsel said no. Whether a person is currently or was previously connected to the partnership is not a factor in deciding if they are eligible to serve as PR. So adding the word "Member" after the signer's name did not invalidate the appointment. This is a narrow, practical clarification for people filling out the form, not a formal ruling.

Ruling snapshot

  • Question: Does adding a title like "Member" on the Form 8979 signature line affect the validity of a person's appointment as Partnership Representative?
  • Outcome: Advice given (no; the appointment was not invalidated).
  • Key authorities: IRC § 6223; Treas. Reg. § 301.6233-1(b) (as cited in the document).

Full text (IRS public release)

 ID:       CCA_2021111013294414                        [Third Party Communication:

 UILC:     6223B.00-00                                 Date of Communication: Month DD, YYYY]

Number: 202208015
Release Date: 2/25/2022
From: ------------------
Sent: Wednesday, November 10, 2021 1:29:44 PM
To: ----------------
Cc: ------------------------
Bcc: ------------------
Subject: RE: ----------------------------- Legitimacy of Partnership Representative Appointment


Hi ---------,

You asked whether adding a title, such as "Member," on the signature line of Form 8979
would impact the legitimacy of a person's appointment as a Partnership Representative
(PR). A PR's current or previous connection to a BBA partnership is not a determinative
factor when considering a person's (or entity's) eligibility to serve as a PR. See Treas.
Reg. 301.6233-1(b). Therefore, ------------appointment as PR on Form 8979 was not
invalidated by his inclusion of the word "Member" after his name. Please let us know if
you have any further questions.

Thanks,
------

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