Ezel / IRS Rulings / 200947045

CCA 200947045: AAR filing need not refile the entire Form 1065

Number
200947045
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Request for Tax Matters Partner
Topics
Procedure, penalties, and administration
Code sections
§ 6227, § 6110
Publicly released
November 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

This Chief Counsel advice addresses an amended partnership filing with Form 8082. It states that the filer needs to submit only the changes to Form 1065 together with Form 8082, rather than an entirely refiled Form 1065.

Ruling snapshot

  • Question: Must an entire Form 1065 be refiled with Form 8082 when requesting an administrative adjustment?
  • Outcome: Advice given
  • Key authorities: IRC § 6227; Form 8082

Full text (IRS public release)

ID: CCA_2009101410173837 Number: 200947045
Release Date: 11/20/2009
Office: ----------
UILC: 6227.02-00

From: -------------------
Sent: Wednesday, October 14, 2009 10:17:44 AM
To: -------------------
Cc: -----------
Subject: RE: TEFRA Partnerships and FBAR Filing Requirements

They just need the changes to the 1065 with a Form 8082. Not an entire refiled 1065.

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