Ezel / IRS Rulings / 201526009
Chief Counsel Advice 201526009 Released June 26, 2015 Advice

TEFRA conversion requires notice covering the partnership issues

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
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 partnership items are converted by an authorized person sending a conversion notice to the ultimate individual or corporate taxpayer under section 6231. After conversion, the IRS has one year to issue a notice of deficiency under section 6229(f). Conversion depends on whether the taxpayer's notice of inconsistent filing covers the partnership issues being converted. If it does not cover those issues, the IRS cannot use the conversion procedure.

Ruling snapshot

  • Question: How are partnership items converted, and when may the IRS issue a resulting notice of deficiency?
  • Outcome: Advice given that conversion requires an authorized notice and a covering notice of inconsistent filing, followed by a one-year deficiency period.
  • Key authorities: IRC §§ 6229(f) and 6231(b); Delegation Order 4-19.

Full text (IRS public release)

ID: CCA_2015042908254501 [Third Party Communication:

UILC: 6222.01-00 Date of Communication: Month DD, YYYY]

Number: 201526009
Release Date: 6/26/2015
From:
Sent: Wednesday, April 29, 2015 8:25:45 AM
To:
Cc:
Bcc:
Subject: RE: Legal Assistance

Conversion occurs through issuing a notice of conversion to the ultimate taxpayer (1040 or 1120) under
section 6231(b)(1)(A) and (b)(2) by a person authorized to send such a conversion notice under
Delegation Order 4-19. We then have one year from the date of conversion to issue a notices of
deficiency to these ultimate taxpayers. I.R.C. 6229(f). This assumes that the Notice of Inconsistent Filing
filed by covers partnership issues that are being
converted. I.R.C. 6231(b)(2). If it doesn’t, we can’t convert. See Example 4 of Treas. Reg. 301.6222-
(a)(2)(d).

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