Ezel / IRS Rulings / 201101023

CCA 201101023: Partners may amend their returns when a non-TEFRA partnership does not amend

Number
201101023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Other Requests
Topics
Procedure, penalties, and administration
Code sections
§ 6227
Ruling dated
November 18, 2010
Publicly released
January 7, 2011
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 2011, 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 2011
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 partners could amend their own returns when a non-TEFRA partnership failed to file an amended return. It concluded that the partnership's failure did not procedurally bar the partners from amending their returns to reflect changes in partnership income. The advice concerns the procedure for reporting partnership-income changes at the partner level.

Ruling snapshot

  • Question: Does a non-TEFRA partnership's failure to file an amended return procedurally bar partners from amending their own returns?
  • Outcome: Advice given
  • Key authorities: IRC § 6227

Full text (IRS public release)

ID: CCA_2010111813390437 Number: 201101023
Release Date: 1/7/2011
Office: ----------
UILC: 6227.05-00

From: --------------------
Sent: Thursday, November 18, 2010 1:39:05 PM
To: ---------------------
Cc: --------------------------------------------------------------------------------------------------
Subject: RE: Amending a NonTEFRA partnership

The failure of a non-TEFRA partnership to file an amended return does not procedurally bar partners from
amending their own return to reflect changes to partnership income.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace