Exception for Small Partnerships

ID:
UILC:
CCA_2014050816270901
6231.01-01
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201421020
Release Date: 5/23/2014
From:
Sent: Thursday, May 08, 2014 4:27:09 PM
To:
Cc:
Bcc:
Subject: RE: Marital Trust- TEFRA
I have coordinated with ---. For years in which the deceased was alive and issued a
K-1 TEFRA would not apply to this otherwise small partnership. For years in which a K-
1 was issued to a Marital Trust as the owner, and not to the estate of the deceased,
TEFRA would apply. You should confirm that the marital trust is a separate entity under state law and not just a reference to the deceased partner’s estate.