Notification

ID: CCA_2009082112103937 Number: 200944030
Release Date: 10/30/2009
Office: ---
UILC: 6222.01-00
From: ---
Sent: Friday, August 21, 2009 12:10:40 PM
To: ---
Cc: ---
Subject: RE: K-1 Discrepancies
Yes. We can issue a valid stat notice if the taxpayer filed a notice of inconsistent treatment but only after sending a notice of conversion under section 6231(b)(2)(A)(i). Under those circumstances a subsequent notice of deficiency would suspend the period for assessment because it would be a valid notice under section 6230(a)(2)(A)(ii) and 6503(a)(first parenthetical).