Ezel / IRS Rulings / 200912014

CCA 200912014: An affected-item notice could determine a partner's outside basis

Number
200912014
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
February 17, 2009
Publicly released
March 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed how to determine a partner's outside basis after a partnership proceeding. The IRS could issue an affected-item notice of deficiency to the partner for that computation. In determining outside basis, the IRS could consider all prior-year partnership items as reported and all items that the partner had treated inconsistently.

Ruling snapshot

  • Question: How could the IRS compute a partner's outside basis after a partnership proceeding?
  • Outcome: Advice given: issue an affected-item notice of deficiency and account for prior reported partnership items and the partner's inconsistently treated items.
  • Key authorities: Affected-item rules under IRC § 6231.

Full text (IRS public release)

ID: CCA_2009021708571837 Number: 200912014
Release Date: 3/20/2009
Office: --------------
UILC: 6231.05-00

From: -------------------
Sent: Tuesday, February 17, 2009 8:57:23 AM
To: ----------------
Cc: -----------
Subject: RE: Inside-Outside Basis Statute question ---------

Following your partnership proceeding, you can issue an affected item notice of deficiency to the partners
to compute his outside basis. All prior year partnership items as reported, and all inconsistently treated
items of the partner can be taken into account in computing his outside basis.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace