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

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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