Ezel / IRS Rulings / 200928041

CCA 200928041: Form 872-I covers limitation periods for converted and unconverted partnership items

Number
200928041
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
May 18, 2009
Publicly released
July 10, 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 advised using Form 872-I for the limitations-period issue presented. The advice says that the form covers both the one-year period under section 6229(d) for unconverted partnership items and the separate one-year period under section 6229(f) for converted items. The short email does not provide additional facts about the partnership or adjustment.

Ruling snapshot

  • Question: Which form covers the one-year limitations periods for both converted and unconverted partnership items?
  • Outcome: Advice given to use Form 872-I
  • Key authorities: IRC § 6229(d), (f)

Full text (IRS public release)

ID: CCA_2009051816342437 Number: 200928041

Release Date: 7/10/2009

Office: ---------

UILC: 6229.02-00

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

Sent: Monday, May 18, 2009 4:34:25 PM

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

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

Subject: RE: TEFRA S/L Question

Use the Form 872-i. Its good for both the one year period under section 6229(d) (for unconverted items) and the separate one year period under section 6229(f)(for converted items).

You can call me to discuss if your like tomorrow.

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