Ezel / IRS Rulings / 201033036

CCA 201033036: One FPAA was probably sufficient to correct an inside basis step-up

Number
201033036
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Partnership Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
July 20, 2010
Publicly released
August 20, 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

Chief Counsel Advice considered how to correct an inside basis step-up in a partnership. The advice stated that the IRS probably needed to issue only one final partnership administrative adjustment, or FPAA, for the identified partnership and beginning date. That adjustment would bind the partner when computing outside basis after selling the partnership interest. The memorandum uses redacted names and dates, so it does not identify the partnership or the transaction details.

Ruling snapshot

  • Question: How many partnership-level adjustments were needed to correct the inside basis step-up?
  • Outcome: advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2010072016293837 Number: 201033036
Release Date: 8/20/2010
Office: ----------
UILC: 6231.03-00

From: -------------------
Sent: Tuesday, July 20, 2010 4:29:40 PM
To: ---------------------
Cc: ------------------------------------------------------------
Subject: RE: TEFRA proceeding questions

We probably only need to issue an FPAA for ------- to correct the inside basis step-up in ------- as of the
beginning of -------. That will be binding on the partner in computing his outside basis when he sold his
interest in -------.

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