Tax Treatment Determined At Partnership Level

ID: CCA_2009040608464437 Number: 200920045
Release Date: 5/15/2009
Office: ---
UILC: 6221.00-00
From: ---
Sent: Monday, April 06, 2009 8:46:46 AM
To: ---
Cc: ---
Subject: RE:
Yes, but the FPAA to X should not be issued until the Y proceeding is over. Under Sente Investment
Club v. Commissioner, 95 T.C. 243 (1990), X will be bound by the determinations in the Y proceeding. X should be treated just like any other partner in this regard and should not get its affected item notice until after the Y proceeding is over (GAF v. Commissioner, 114 T.C. 519 (2000)), unless Y has independent items that need to be determined now.