Exception for Small Partnerships

ID: CCA_2010093014491837 Number: 201042032
Release Date: 10/22/2010
Office: ---
UILC: 6231.01-01
From: ---
Sent: Thursday, September 30, 2010 2:49:21 PM
To: ---
Cc: ---
Subject: RE: TEFRA/non-TEFRA/DUAL PROCEDURES
The TEFRA partnership provisions do not apply to a flow through entity owned by a single person, even if that person holds both a limited and unlimited interest even if the entity has made a purported election to be governed by TEFRA. Thus, only non-TEFRA deficiency procedures apply to the sole owner of the entity.
---
---