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Chief Counsel Advice 1034023 Released August 27, 2010 Advice

CCA 1034023: Chief Counsel addressed the timing of an NBAP

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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

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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