Ezel / IRS Rulings / 201024060

CCA 201024060: The IRS cannot add items to an FPAA that it has already issued

Number
201024060
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension to Entities Filing Partnership Returns, Etc.
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 6110
Ruling dated
May 12, 2010
Publicly released
June 18, 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

The Office of Chief Counsel advised that the IRS may issue only one final partnership administrative adjustment for a taxable year under IRC § 6223(f). As a result, the IRS could not add additional items to the FPAA it had already issued. The memo responds to a question about an incorrect explanation of items in a partnership proceeding.

Ruling snapshot

  • Question: May the IRS add items to an FPAA after issuing it?
  • Outcome: Advice given
  • Key authorities: IRC § 6223(f)

Full text (IRS public release)

ID: CCA_2010051213562637 Number: 201024060
Release Date: 6/18/2010
Office: --------
UILC: 6233.00-00

From: --------------------
Sent: Wednesday, May 12, 2010 1:57:09 PM
To: --------------------
Cc: ------------
Subject: RE: Wrong Explanation of Items to TMP FPAA

We can only issue one FPAA. I.R.C. 6223(f). So we cannot add anything to the FPAA we already
issued.

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