Ezel / IRS Rulings / 201109024

CCA 201109024: A section 481 adjustment is a partnership item

Number
201109024
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Section 481 Adjustment
Topics
Procedure, penalties, and administration
Code sections
§ 481, § 6231
Ruling dated
February 7, 2011
Publicly released
March 4, 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 the classification of a section 481 adjustment for partnership tax purposes. It concluded that the adjustment is a partnership item under Treas. Reg. § 301.6231(a)(3)-1(b).

Ruling snapshot

  • Question: Is a section 481 adjustment a partnership item?
  • Outcome: Advice given.
  • Key authorities: IRC §§ 481 and 6231; Treas. Reg. § 301.6231(a)(3)-1(b).

Full text (IRS public release)

ID: CCA_2011020714472637 Number: 201109024
Release Date: 3/4/2011
Office: ----------
UILC: 6231.03-00

From: -------------------
Sent: Monday, February 07, 2011 2:47:33 PM
To: -------------------
Cc: -----------
Subject: RE: 481(a) adjustment

A section 481 adjustment is a partnership item under Treas. Reg. 301.6231(a)(3)-1(b).

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