Ezel / IRS Rulings / 202417017
Chief Counsel Advice 202417017 Released April 26, 2024 Advice

Partners calculate their own tax changes after a BBA push out

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This page covers one taxpayer's ruling from 2024, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

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 addressed who performs the tax calculation after a partnership subject to the centralized BBA audit rules elects to push adjustments out to its partners. Each partner computes the change in tax that would have resulted from the pushed-out adjustments. For simplicity, the advice says that change is reflected on the partner's next filed return. The IRS does not perform that calculation, so the examining employee would not need the type of computation memorandum under discussion.

Ruling snapshot

  • Question: Does the IRS calculate each partner's tax change after a BBA partnership pushes out adjustments?
  • Outcome: advice given
  • Key authorities: Centralized partnership audit push-out rules; UILC 6232.00-00

Full text (IRS public release)

 ID:        CCA_2024032913475948                   [Third Party Communication:

 UILC:      6232.00-00 R 1988                      Date of Communication: Month DD, YYYY]

Number: 202417017
Release Date: 4/26/2024
From: --------------------
Sent: Tuesday, January 9, 2024 7:55:58 AM
To: -----------------------
Cc: --------------------------------------------
Bcc:
Subject: RE: SCE Settlement


Hi -----,

If the BBA partnership elects to push out the adjustments to its partners, the partners
compute what their change in tax would have been and it is reflected on their (for
simplicity’s sake) next filed return. The IRS does not do this calculation. So you would
not need a memo like this.

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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