Administrative Adjustments Requests

ID: CCA_2010113016384837 Number: 201102060
Release Date: 1/14/2011
Office: ---
UILC: 6227.00-00
From: ---
Sent: Tuesday, November 30, 2010 4:38:52 PM
To: ---
Cc: ---
Subject: RE: Statute of Limitations - AAR
A request for administrative adjustment has to be filed within 3 years of the date the partnership return was filed or within an extension of the section 6229 period for that year plus 6 months. I.R.C. 6227(b).
So it is too late for partners to file an AAR unless the Forms 872-i for later carryforward years are considered to hold open the year 1 partnership items. The extensions would not hold open the statue for a deduction for year 1. Your facts are unclear as to whether the deductions would have been fully deductible in Year 1 if they had been properly characterized.