CCA 201018010
Exception for Small Partnerships
ID: CCA_2010041310400037 Number: 201018010
Release Date: 5/7/2010
Office: ---
UILC: 6231.01-01
From: ---
Sent: Tuesday, April 13, 2010 10:40:02 AM
To: ---
Cc: ---
Subject: RE: TEFRA question
TEFRA does not apply to the small partnership because they made no election under section 6231(a)(1) and so stated on the return.
Both TEFRA and non-TEFRA partnerships commonly have tax matters partners that are reflected on the partnership return (even though this is only necessary for TEFRA partnerships). So the fact that a TMP was identified does not rebut the explicit statement that no TEFRA election was filed.
Source: view the official PDF
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