Ezel / IRS Rulings / 200913016

CCA 200913016: Later changes to converted items were outside consistent-settlement rules

Number
200913016
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Ancillary Consistent Agreements
Topics
Procedure, penalties, and administration
Code sections
§ 6224
Ruling dated
June 26, 2008
Publicly released
March 27, 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 answered a question about consistent settlements of partnership items. Once the items had converted from partnership items, a later modification was not governed by the consistent-agreement rules. The brief release provides no facts about the items, their conversion, or the proposed modification.

Ruling snapshot

  • Question: Did consistent-agreement rules apply to a modification made after partnership items had converted?
  • Outcome: Advice given: no, a later modification was outside those rules.
  • Key authorities: IRC § 6224 consistent-settlement rules.

Full text (IRS public release)

ID: CCA-626958-08 Number: 200913016
Release Date: 3/27/2009
Office: --------------
UILC: 6224.01-04

From: -------------------
Sent: Thu 6/26/2008 9:58 AM
To: ----------------------
Cc:
Subject: RE: Consistent Settlement Question

Once items have converted, any latter modification is not subject to consistent agreements.

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