Ezel / IRS Rulings / 1219018
Chief Counsel Advice 1219018 Released May 11, 2012 Advice

CCA 1219018: IRS advice on combining partnership proceedings for multiple years

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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 addresses whether a single final partnership administrative adjustment can cover more than one tax year. The default rule is to issue a separate FPAA for each year because the partners may differ between years. The advice permits two or more years to be combined in one FPAA when the linkages are identical for those years.

Ruling snapshot

  • Question: When may FPAAs for multiple partnership tax years be combined?
  • Outcome: Advice given
  • Key authorities: IRC § 6223

Full text (IRS public release)

ID: CCA_2012040610333737 Number: 201219018
Release Date: 5/11/2012
Office: ----------
UILC: 6223.00-00

From: -------------------
Sent: Friday, April 06, 2012 10:33:47 AM
To: ---------------------
Cc: --------------------------
Subject: RE: Separate FPAA is required to be issued for each tax period?

The default rule is that a separate FPAA should be issued for each separate year, since the partners may
be different.

If the linkages are identical for both years, however, we are allowed to combine two or more years in the
same FPAA.

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