Ezel / IRS Rulings / 201202025

CCA 201202025: CCA addresses a bankrupt partner's converted items

Number
201202025
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Items Cease to Be Partnership Items in Certain Cases
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6230, § 6501, § 6229
Ruling dated
December 19, 2011
Publicly released
January 13, 2012
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 2012, 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 2012
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 a bankrupt partner whose partnership items had converted to nonpartnership items under Treasury Regulation § 301.6231(c)-7. The advice states that the IRS must issue a converted-item notice of deficiency under section 6230(a)(2)(A)(ii) within the later of the partner's section 6501 assessment period or one year after conversion under section 6229(f). The memorandum provides this timing conclusion without additional factual analysis.

Ruling snapshot

  • Question: When must the IRS issue a notice of deficiency for a bankrupt partner's converted nonpartnership items?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6230(a)(2)(A)(ii), 6501, and 6229(f); Treas. Reg. § 301.6231(c)-7

Full text (IRS public release)

ID: CCA_2011121914075137 Number: 201202025
Release Date: 1/13/2012
Office: ----------
UILC: 6231.13-00

From: -------------------
Sent: Monday, December 19, 2011 2:07:59 PM
To: --------------------------
Cc: -----------
Subject: RE: TEFRA exams with bankrupt partner

Yes. For a bankrupt partner whose partnership items have converted to nonpartnership items under
Treas. Reg. 301.6231(c)-7, we must issue a converted item notice of deficiency under section
6230(a)(2)(A)(ii) within the later of the partner's section 6501 period for assessment or one year from the
date of conversion under section 6229(f).

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