Ezel / IRS Rulings / 201107021

CCA 201107021: Partnership-level proceedings require notice under § 6223(a)(1)

Number
201107021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice to Partners of Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6223, § 7605
Ruling dated
January 20, 2011
Publicly released
February 18, 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 contrasts the general one-inspection rule in IRC § 7605(b) with the partnership-level notice requirement in IRC § 6223(a)(1). Section 7605(b) generally permits only one inspection of a taxpayer's books of account, subject to listed exceptions. Section 6223(a)(1) requires notice of the beginning of an administrative proceeding at the partnership level concerning a partnership item. The specific exam question and additional facts are redacted in the public release.

Ruling snapshot

  • Question: How do the one-inspection rule and the partnership-level proceeding notice requirement apply to an exam?
  • Outcome: Advice given.
  • Key authorities: IRC §§ 6223(a)(1) and 7605(b).

Full text (IRS public release)

ID: CCA_2011012010403637 Number: 201107021
Release Date: 2/18/2011
Office: ----------
UILC: 6223.00-00

From: -------------------
Sent: Thursday, January 20, 2011 10:40:40 AM
To: --------------------
Cc: -----------
Subject: RE: Initiating an exam

Section 7605(b) generally requires "only one inspection of a taxpayer's books of account" subject to listed
exceptions. Section 6223(a)(1) requires the issuance a notice of "the beginning of an administrative
proceeding at the partnership level with respect to a partnership item [NBAP]." -----------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------

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