Ezel / IRS Rulings / 201034023

CCA 201034023: Chief Counsel addressed the timing of an NBAP

Number
201034023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice to Partners of Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6223
Ruling dated
July 29, 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 the timing of a notice of final partnership administrative adjustment, or NBAP. The advice states that an NBAP must be issued at least 120 days before an FPAA is issued. It also states that § 6223(d) contains no other specific statutory timing requirement for an NBAP.

Ruling snapshot

  • Question: What statutory timing requirement applies to issuing an NBAP before an FPAA?
  • Outcome: Advice given
  • Key authorities: IRC § 6223(d)

Full text (IRS public release)

ID: CCA_2010072910525737 Number: 201034023
Release Date: 8/27/2010
Office: ---------
UILC: 6223.00-00

From: --------------------
Sent: Thursday, July 29, 2010 10:53:03 AM
To: -----------------------
Cc: ------------
Subject: RE: NBAP QUESTIONS

An NBAP must be issued at least 120 days before an FPAA is issued. I.R.C. 6223(d). There is no other
specific statutory requirement for the timing of an NBAP.

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