Treatment of Electing Large Partnerships

ID: CCA_2009020208575037 Number: 200911017
Release Date: 3/13/2009
Office: ---
UILC: 6240.00-00
From: ---
Sent: Monday, February 02, 2009 8:57:52 AM
To: ---
Cc: ---
Subject: RE: ELP Tier
Section 6240(b)(2) allows us to take the TEFRA partnership items into account only at the electing large partnership level under section 6242. In other words, when the TEFRA partnership items are finally determined, they are included in the electing large partnership's return for the later year when the adjustments finally take effect. They are then included in the Schedules K-1 issued by the electing large partnership. Or the ELP may, instead, just pay the tax.