Ezel / IRS Rulings / 200914038

CCA 200914038: An affected-items deficiency notice should adjust a partner's outside basis

Number
200914038
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Coordination with Deficiency Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
March 4, 2009
Publicly released
April 3, 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 considered the procedure for adjusting a partner's outside basis in a partnership. It advised the IRS to issue an affected-items notice of deficiency making that adjustment. The one-sentence answer provides no facts about the partnership, the underlying partnership-item determination, or the amount of the basis adjustment.

Ruling snapshot

  • Question: What procedure should the IRS use to adjust a partner's outside basis in a partnership?
  • Outcome: Advice given: issue an affected-items notice of deficiency.
  • Key authorities: IRC § 6230.

Full text (IRS public release)

ID: CCA_2009030409402854 Number: 200914038
Release Date: 4/3/2009
Office: --------------
UILC: 6230.01-00

From: --------------------------
Sent: Wednesday, March 04, 2009 9:40:30 AM
To: ----------------
Cc: --------------------
Subject: RE: Partnership Items

The Service should issue an affected items notice of deficiency that adjusts the partner's outside basis in
the partnership.

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