Ezel / IRS Rulings / 1024060
Chief Counsel Advice 1024060 Released June 18, 2010 Advice

CCA 1024060: The IRS cannot add items to an FPAA that it has already issued

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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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