Erroneous examination letter did not need reissuance after partnership audit notice

Number

202547017

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Period of Limitations on Making Adjustments

Topics

Procedure, penalties, and administration

Code sections

§ 6235

Ruling dated

April 7, 2025

Publicly released

November 21, 2025

Source

View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2025, 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 was asked whether the IRS needed to reissue Letter 2205-D after a notice of administrative proceeding had already been issued in a centralized partnership audit. The advice said no. Letter 2205-D is not required by statute under the partnership audit rules. An error in that letter therefore did not affect the IRS's ability to issue a final partnership adjustment.

Ruling snapshot

Question: Must the IRS reissue Letter 2205-D after it has already issued the partnership audit notice?
Outcome: Advice given, reissuance was unnecessary
Key authorities: IRC § 6235; centralized partnership audit rules

Full text (IRS public release)

ID: CCA_2025082208101200 [Third Party Communication:

UILC: 6235B.00-00 Date of Communication: Month DD, YYYY]

Number: 202547017
Release Date: 11/21/2025
From: --------------------
Sent: Monday, April 7, 2025 07:06:12 AM
To: ------------------------
Cc: ------------------
Bcc:
Subject: RE: BBA L2205-D Error

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

The Letter 2205-D does not need to be re-issued because, as you pointed out, the NAP has
already been issued. The Letter 2205-D is not statutorily required under BBA and does not
impact the issuance of the FPA. Please let us know if you have further questions.

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