Administrative Adjustments Requests

ID: CCA_2009100815201654 Number: 200947048
Release Date: 11/20/2009
Office: ---
UILC: 6227.00-00
From: ---
Sent: Thursday, October 08, 2009 3:20:19 PM
To: ---
Cc: ---
Subject: RE: TEFRA Partnerships and FBAR Filing Requirements
No, because Forms 5471 and 5472, alone, do not include all statements required by Form 8082 or all statements necessary to substantial compliance with the requirements of Form 8082. See Samueli v.
Comm'r, 132 T.C. No. 16, 2009 WL 1397177, quoting I.R.M 4.31.4.2.3.1(1)("Any partner may file an AAR on his or her own behalf. In order to file an AAR, a partner must complete an amended return and Form 8082 or statements that provide the same information required by Form 8082.").