Release number 202433010 of 2024-08-16

• Date: 16 August 2024
• Year: 2024
• Record Number: 202433010
• UILC Number: 9999.00-00

ID:

UILC:

CCA_2023080212520843

9999.00-00

[Third Party Communication:

Date of Communication: Month DD, YYYY]

Number: 202433010

Release Date: 8/16/2024

From:--------------------

Sent: Monday, July 1, 2024 7:34:56 PM

To:-----------------------------------------------

Cc:----------------

Bcc:

Subject: RE: BBA Question

If a disregarded entity owns the interest in the partnership, it is the partner. See

Seaview Trading v. Comm’r, 858 F.3d 1281 (9thCir. 2017). A reviewed year partner

signs the Form 8979 so if the disregarded entity was a partner in the reviewed year,

whoever can bind that disregarded entity under state law would sign the Form 8979.

Note that so long as the correct human being signs the form, it doesn’t really matter

what the person puts as their title (if any).

Please let me know if you have any questions.

Thanks,

Jenni

Jenni Black (she/her)

Senior Counsel

CC:PA:06

Phone: (202) 317-5216