Ezel / IRS Rulings / 201024061

CCA 201024061: Mitigation provisions apply to TEFRA adjustments and related correlative adjustments

Number
201024061
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Correction of Error
Topics
Other topics
Code sections
§ 1311, § 6231, § 6110
Ruling dated
May 13, 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 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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