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,...

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