Ezel / IRS Rulings / 1202025
Chief Counsel Advice 1202025 Released January 13, 2012 Advice

CCA 1202025: CCA addresses a bankrupt partner's converted items

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This page covers one taxpayer's ruling from 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 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 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).

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