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Ezel / IRS Rulings / 201710028
Chief Counsel Advice 201710028 Released March 10, 2017 Advice

State-law authority controls who signs for an entity TMP

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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

Chief Counsel confirmed who may sign documents when a TEFRA partnership's tax matters partner is itself an entity. The person authorized under state law to act for that entity may sign an agreement extending the limitations period. As an added safeguard, the IRS may obtain extensions from the ultimate taxpayers who would be assessed after the partnership proceeding. For a settlement involving a pass-through partner, Treasury Regulation section 301.6224(c)-2(b) governs, and a state-law manager signs when the partner is an LLC.

Ruling snapshot

  • Question: Who may sign TEFRA limitations extensions and settlement agreements for entity tax matters partners and pass-through partners?
  • Outcome: advice given
  • Key authorities: IRC §§ 6224 and 6229; Treas. Reg. § 301.6224(c)-2(b)

Full text (IRS public release)

ID: CCA_2017030108361143
UILC: 6224.01-01, 6229.02-00

Number: 201710028
Release Date: 3/10/2017
From:
Sent: Wednesday, March 01, 2017 8:36:11 AM
To:
Cc:
Bcc:
Subject: RE: TEFRA Questions

Hi -----,

Your analysis is correct. If the TMP of a TEFRA partnership is an entity, the statute
extension is signed by whoever has the authority, under state law, to sign for the TMP-
entity. If you have any concerns, you could also get statute extensions from the ultimate
taxpayers who would be assessed following the conclusion of the partnership
proceeding. For settlement agreements with pass-through partners, Treas. Reg.
301.6224(c)-2(b) identifies who signs for the pass-through partner. If the pass-through
partner is an LLC, a manager under state law signs for the LLC.

Please let me know if you have any questions.

Thanks,

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