Ezel / IRS Rulings / 1149025
Chief Counsel Advice 1149025 Released December 9, 2011 Advice

No-change partnership result can produce a partner-level adjustment

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This page covers one taxpayer's ruling from 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 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 effect of a no-change result for partnership items at the partnership level. It stated that the result can still produce a computational adjustment at the partner level that may be assessed or refunded under section 6230. The advice also gave an inconsistent partnership return under section 6222 as an example and said the Service may issue a no-change FPAA to make the adjustment.

Ruling snapshot

  • Question: Can a no-change partnership-level result produce a partner-level computational adjustment?
  • Outcome: advice given
  • Key authorities: IRC §§ 6230(a), 6230(c), and 6222; Bush v. United States, - F.3d - (Fed. Cir. 2011); Harbor Cove v. Commissioner.

Full text (IRS public release)

ID: CCA_2011120512473537 Number: 201149025
Release Date: 12/9/2011
Office: ----------
UILC: 6230.00-00

From: -------------------
Sent: Monday, December 05, 2011 12:47:41 PM
To: -------------------
Cc: -----------
Subject: RE: Opinion needed on statutes for a Tefra linked investor which is a Joint Committee case

Yes. As explained by a recent opinion of the Federal Circuit in Bush v. U.S., - F.3d - (Fed. Cir. 2011) , a
no change to partnership items at the partnership level still results in a "computational adjustment" of
partnership items at the partner level that can be assessed or refunded under section 6230(a) or (c). For
instance, if a partner files inconsistently with a partnership return under section 6222, we may issue a no
change FPAA in order to make a computational adjustment to that partner. Cf. Harbor Cove v.
Commissioner (partner disagreed with no change FPAA).

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