Final partnership adjustments need not match the proposed notice

Number
202417013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice of Proceedings and Adjustments
Code sections
§ 6231
Ruling dated
January 5, 2024
Publicly released
April 26, 2024

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2024, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, 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 adjustments in a final partnership adjustment do not have to match those in the earlier notice of proposed partnership adjustment. The earlier notice contains proposed rather than final adjustments. When the final document is prepared, adjustments may be changed, added, or removed if appropriate. An examining employee may therefore recommend changes before the final partnership adjustment is issued.

Ruling snapshot

  • Question: Must the adjustments in a final partnership adjustment match those in the proposed notice?
  • Outcome: advice given
  • Key authorities: BBA notice and final partnership adjustment procedures; UILC 6231B.00-00

Full text (IRS public release)

 ID:       CCA_2024010513025143             [Third Party Communication:

 UILC:     6231B.00-00                      Date of Communication: Month DD, YYYY]

Number: 202417013
Release Date: 4/26/2024
From: --------------------
Sent: Friday, January 5, 2024 1:02:51 PM
To: -------------------
Cc:
Bcc:
Subject: RE: FPA procedural question


Hi ----------,

The adjustments in the FPA do not have to match the adjustments in the NOPPA. The
NOPPA contains proposed adjustments as opposed to final ones. As such, adjustments
can be changed, added, or removed when the FPA is prepared, if appropriate.
Therefore, there is no issue with you recommending that the adjustments be changed
prior to the issuance of the FPA.

Please let me know if you have any questions.

Thanks,
Jenni

Jenni Black (she/her)
Senior Counsel
CC:PA:06
Phone: (202) 317-5216

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