Ezel / IRS Rulings / 1244019
Chief Counsel Advice 1244019 Released November 2, 2012 Advice

CCA 1244019: Prompt assessment conversion depends on the status of the TEFRA proceeding

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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 advised that a request for prompt assessment under IRC § 6501(d) converts partnership items only if the TEFRA proceeding is not yet complete. The advice states that the conversion does not occur if the partnership items have already been finally determined.

Ruling snapshot

  • Question: When does a prompt-assessment request convert partnership items?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6231, 6501(d), and 6110; Treas. Reg. §§ 301.6231(c)-3 and 301.6231(c)-8

Full text (IRS public release)

ID: CCA_2012090713251237 Number: 201244019
Release Date: 11/2/2012
Office: ----------
UILC: 6231.14-00

From: --------------------
Sent: Friday, September 07, 2012 1:25:37 PM
To: --------------------------------------------
Cc: ------------

Subject: RE: Prompt Assessment on a 10/15/12 Statute

A request for prompt assessment under section 6501(d) only converts partnership items if the TEFRA
proceeding is not yet complete. Treas. Reg. 301.6231(c)-8(prompt assessment conversion) and -3 (no
conversion if partnership items have already been finally determined).

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