Sunday, June 3, 2012

No partnership

CCA 201221015

UIL No. 7701.02-00




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. ——————

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