No partnership

CCA 201221015






UIL No. 7701.02-00



Headnote:



Reference(s):



FULL TEXT:

Number: 201221015



Release Date: 05/25/2012



Number: 201221015ID: CCA_2012030712424338



Release Date: 5/25/2012 Office: —————



UILC: 7701.02-00



From: ———————— Sent: Wednesday, March 07, 2012 12:43:18 PM To: —————————- Cc:



Subject: RE: Advice requested; short statute ———-



Your instincts are correct. There is no partnership. ——- is disregarded as separate from —— and thus isn't considered a partner for federal tax purposes. The only owner for federal tax purposes is ——. One owner, no partnership.



Let me know if you need anything else. ——————