Partner's Distributive Share

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 201721013
Release Date: 5/26/2017
CC:PSI:03:ARCarmody
PRENO-106365-17
Third Party Communication: None
Date of Communication: Not Applicable
UILC: 704.00-00 date: February 23, 2017 to: William G. Merkle, Area Counsel (Retailers, Food, Pharmaceuticals & Healthcare) (Large Business & International) from: Richard T. Probst Senior Technician Reviewer, Branch 3 (Passthroughs & Special Industries) subject: TAM-136522-15 This Chief Counsel Advice (CCA) responds to your request for assistance. This advice may not be used or cited as precedent.
This CCA accompanies TAM-136522-15. Please see that document for a full recitation of facts, issues, law, analysis, and conclusions.
CASE DEVELOPMENT, HAZARDS AND OTHER CONSIDERATIONS
PRENO-106365-17 2
This writing may contain privileged information. Any unauthorized disclosure of this writing may undermine our ability to protect the privileged information. If disclosure is determined to be necessary, please contact this office for our views.
Please call 202-317-5279 if you have any further questions.