Ezel / IRS Rulings / 201034021

CCA 201034021: A partnership cannot have an affected item in itself

Number
201034021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
July 28, 2010
Publicly released
August 27, 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 addressed whether a partnership could have an affected item in itself. The advice concluded that it could not. Each partnership year is a separate cause of action, and partnership items for one year are not computationally affected by adjustments to other partnership years. Therefore, an amortization for one year does not keep the statute open for other partnership years as affected items.

Ruling snapshot

  • Question: Can a partnership have an affected item in itself?
  • Outcome: Advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2010072814355537 Number: 201034021
Release Date: 8/27/2010
Office: ---------
UILC: 6231.05-00

From: --------------------
Sent: Wednesday, July 28, 2010 2:35:57 PM
To: -------------------
Cc: ------------
Subject: RE: Question about language requested to be added to 870-PT(AD)

A partnership cannot have an affected item in itself. Each partnership year is a separate cause of action
whose partnership items are not computationally affected by adjustments to other partnership years.
Thus, an amortization for one year will not keep the statute open for other partnership years as "affected
items".

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