Ezel / IRS Rulings / 1320018
Chief Counsel Advice 1320018 Released May 17, 2013 Advice

CCA 1320018: Partners may file their own AARs only while their statutes remain open

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This page covers one taxpayer's ruling from 2013, 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 2013
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

The memorandum addresses whether partners may file their own administrative adjustment requests. It states that they may do so only if the statute of limitations remains open under their own Forms 872. The memorandum cites IRC § 6227(b) and (d).

Ruling snapshot

  • Question: May partners file their own administrative adjustment requests after the applicable statute has closed?
  • Outcome: Advice given
  • Key authorities: IRC § 6227(b) and (d)

Full text (IRS public release)

ID: CCA_2013042913460501 Third Party Communication: None

UILC: 6227.05-00 Date of Communication: Not Applicable

Number: 201320018
Release Date: 5/17/2013
From:
Sent: Monday, April 29, 2013 1:46:06 PM
To:
Cc:
Bcc:
Subject: RE: Question on AAR Statutes involving investors

The partners cannot file their own AAR’s unless their statute is open pursuant to their own
Forms 872. I.R.C. 6227(b) and (d).

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