Ezel / IRS Rulings / 201014058

CCA 201014058: IRS discusses an omitted partnership item

Number
201014058
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partner's Return Must Be Consistent with Partnership Return or Secretary Notified of Inconsistency
Topics
Procedure, penalties, and administration
Code sections
§ 6222
Ruling dated
March 4, 2010
Publicly released
April 9, 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 states that if a partner failed to include an income item, section 6222 permits the IRS to assess the inconsistently reported item. The partnership return controls the years in which the item should be included. The advice also states that no valid administrative adjustment request was filed.

Ruling snapshot

  • Question: Could the IRS assess an income item that a partner omitted when the partnership return controlled the year of inclusion?
  • Outcome: Advice given
  • Key authorities: IRC § 6222

Full text (IRS public release)

ID: CCA_2010030411251237 Number: 201014058
Release Date: 4/9/2010
Office: ----------
UILC: 6222.00-00

From: -------------------
Sent: Thursday, March 04, 2010 11:25:16 AM
To: ---------------------
Cc: -----------
Subject: RE: [ -------------]

If the partner failed to include the income section 6222 allows us to assess the inconsistently reported
item. The partnership return controls which years it should be included on.

No valid AAR was filed.

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