Ezel / IRS Rulings / 1024061
Chief Counsel Advice 1024061 Released June 18, 2010 Advice

CCA 1024061: Mitigation provisions apply to TEFRA adjustments and related correlative adjustments

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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 mitigation provisions apply to TEFRA adjustments and open the statute of limitations for making correlative adjustments. It further stated that applying the mitigation provisions to a partnership item is itself a partnership item under Treas. Reg. § 301.6231(a)(3)-1(b).

Ruling snapshot

  • Question: Do mitigation provisions apply to TEFRA adjustments and the related correlative adjustments?
  • Outcome: Advice given
  • Key authorities: IRC § 1311; Treas. Reg. § 301.6231(a)(3)-1(b)

Full text (IRS public release)

ID: CCA_2010051312101737 Number: 201024061
Release Date: 6/18/2010
Office: --------
UILC: 1311.00-00

From: --------------------
Sent: Thursday, May 13, 2010 12:11:01 PM
To:
Cc:
Subject: RE: Affected Item vs Partnership Item

Mitigation applies to TEFRA adjustments and would open the statute for making the correlative
adjustments. The application of the mitigation provisions to a partnership item would be a partnership
item itself under Treas. Reg. 301.6231(a)(3)-1(b).

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