Definitions and Special Rules

ID:
Office:
UILC:
CCA_2010051408592137
---
6231.00-00
Number: 201024062
Release Date: 6/18/2010
From: ---
Sent: Friday, May 14, 2010 9:00:04 AM
To:
Cc:
Subject: RE: Possible munro situation
If the taxpayer reported a $ loss, and we have a $ + non-TEFRA adjustment we would determine a deficiency on approximately $ of net income.
If we if ignore the net income from the partnership (also about $ ), the starting "reported amount" would be a negative $ . This would result in a de minimus deficiency. When the TEFRA proceeding is over, we will likely only be able to asses additional partnership income and we will have forgone our ability to assess a deficiency on the $ of net non-TEFRA income.
So I agree that we should not use the Munro computations under this scenario.