CCA 201101011
Settlement Agreement
ID: CCA_2010100612164837 Number: 201101011
Release Date: 1/7/2011
Office: ---
UILC: 6224.01-01
From: ---
Sent: Wednesday, October 06, 2010 12:16:51 PM
To: ---
Cc: ---
Subject: RE: CASES RECEIVED ---
---
--- Technically a settlement agreement with the pass-thru partner would be sufficient under section 6224(c)(1)(last sentence). There is no requirement that the pass-thru partner's statute be open in order to execute such an agreement and, in any event, a pass-thru partner has no statute of limitations on assessment since it is not a taxpayer and files an information return rather than a tax return.
Source: view the official PDF
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