Ezel / IRS Rulings / 1024064
Chief Counsel Advice 1024064 Released June 18, 2010 Advice

CCA 1024064: The IRS may issue only one FPAA for a taxable year under section 6223(f)

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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 confirmed that IRC § 6223(f) permits the IRS to issue only one final partnership administrative adjustment for a taxable year. The memo contrasts that rule with IRC § 6230(a)(2)(C). It responds to a follow-up question about TEFRA partnership proceedings.

Ruling snapshot

  • Question: How many FPAAs may the IRS issue for a partnership’s taxable year under IRC § 6223(f)?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6223(f) and 6230(a)(2)(C)

Full text (IRS public release)

ID: CCA_2010051709145637 Number: 201024064
Release Date: 6/18/2010
Office: --------
UILC: 6223.00-00

From: --------------------
Sent: Monday, May 17, 2010 9:14:59 AM
To:
Cc:
Subject: RE: Follow-up TEFRA question

You are correct. Section 6223(f), unlike section 6230(a)(2)(C), allows us to only issue one FPAA for a
taxable year.

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