Welcome
Daily Tax Report ®

IRS CCA: Issuance of Multiple Final Partnership Administrative Adjustments Rare (IRC §6223)

Feb. 14, 2020, 7:11 PM

Multiple final partnership administrative adjustments (FPAA) are not usually possible because when making adjustments in examination of the partnership the IRS may only issue one FPAA for a particular taxable year absent fraud, malfeasance, or misrepresentation of a material fact, the Chief Counsel’s Office informally advised. The Chief Counsel’s noted that in a limited circumstance where a Tax Equity and Fiscal Responsibility Act (TEFRA) partnership (TP2) is a partner to another TEFRA partnership (TP1) and a partner-level fact determination is needed at the TP2 level in order to apply the results of the financial determination in the TP1 TEFRA proceeding,...

To read the full article log in. To learn more about a subscription click here.