Partner's Return Must Be Consistent with Partnership Return or Secretary Notified of Inconsistency

ID: CCA_2009070108403037 Number: 200932051
Release Date: 8/7/2009
Office: ---
UILC: 6222.00-00
From: ---
Sent: Wednesday, July 01, 2009 8:40:32 AM
To: ---
Cc: ---
Subject: RE: 2007 proposed adjustment to TEFRA case ---
Section 704(c) allocations are partnership items under Treas. Reg. 301.6231(a)(3)-1. So you can address them, but the determination would be a "no change" if the items are correctly reported on the attachments to the Schedules K-1. Since the partners filed inconsistently with thier Schedule K-1 (the attachment to the K-1 is deemed part of the K-1) we can directly assess now under section 6222. Or we can wait and assess once the partnership proceeding is complete along with any other items determined in the TEFRA proceeding.