IRS Chief Counsel: Partnership control system requirements

Partnership control system requirements

The IRS today publicly released a memorandum* concerning the requirements for the IRS to link partners during a partnership-level examination and the issuance of notices. AM2015-003 (release date February 27, 2015, and dated February 23, 2015)

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The IRS memo concludes that the partnership control system is simply a tool used by the IRS in the course of TEFRA partnership examinations. There are no legal requirements to link or not link any, all, or some partners in a partnership. Similarly, de-linking a partner has no legal impact and there are no notice requirements that would apply.

The memo also states that the IRS is not required to issue any notice to a partner if it decides not to make adjustments to the partnership return and it does not need to notify a partner that it will not be making an assessment.


Read AM2015-003 [PDF 45 KB]


*The memorandum is legal advice, signed by executives in the National Office of the Office of Chief Counsel and issued to IRS personnel who are national program executives and managers. The memo is issued to assist IRS personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. It is not to be used or cited as precedent.

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