Ezel / IRS Rulings / 201013041

CCA 201013041: IRS directs where contribution changes belong in an FPAA

Number
201013041
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partnership Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
February 26, 2010
Publicly released
April 2, 2010
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 2010, 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 2010
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 advice addressed how changes to a contribution amount should be recorded in a TEFRA partnership proceeding. It stated that the changes should appear on the Schedule of Adjustments in the Final Partnership Administrative Adjustment.

Ruling snapshot

  • Question: Where should changes to a contribution amount be recorded in an FPAA?
  • Outcome: Advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2010022610233137 Number: 201013041
Release Date: 4/2/2010
Office: ----------
UILC: 6231.03-00

From: -------------------
Sent: Friday, February 26, 2010 10:23:33 AM
To: -------------------------------------------------------------------------------------------------------------------------
Cc: -----------
Subject: RE: TEFRA ---------

The contribution amount changes should go on the Schedule of Adjustments in the FPAA.

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