Ezel / IRS Rulings / 1326017
Chief Counsel Advice 1326017 Released June 28, 2013 Advice

CCA 1326017: A payment by a partnership to a partner is a partnership item

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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 Chief Counsel's Office addressed the tax treatment of an amount paid by a partnership to a partner. It concluded that the payment is a partnership item. Changing the amount reported by the partnership would therefore require the IRS to issue a final partnership administrative adjustment, or FPAA.

Ruling snapshot

  • Question: What procedural treatment applies when a partnership reports an amount paid to a partner incorrectly?
  • Outcome: Advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2013061008363901 Third Party Communication: None

UILC: 6231.03-00 Date of Communication: Not Applicable

Number: 201326017
Release Date: 6/28/2013
From:
Sent: Monday, June 10, 2013 8:36:39 AM
To:
Cc:
Bcc:
Subject: RE: Affected Item?

The amount paid by a partnership to a partner is a partnership item. To change the
value of the paid amount reported by the partnership, we would have to issue and FPAA.

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