CCA 201108032
Ancillary Consistent Agreements
ID: CCA_2011012609291337 Number: 201108032
Release Date: 2/25/2011
Office: ---
UILC: 6224.01-04
From: ---
Sent: Wednesday, January 26, 2011 9:29:17 AM
To: ---
Cc: ---
Subject: RE: inconsistency issue in --- case
I am not sure I understand your facts. It sounds like we issued an FPAA for both---and --- when we only should have issued it for only ---. Is that correct? We cannot now issue another FPAA for either year. I.R.C. 6223(f). For the partners who have already settled both years the settlement is final and binding and should be processed. I.R.C. 6224(c)(1). The remaining partners would likely be entitled to the same settlement if they want it. See I.R.C. 6224(c)(2).
Source: view the official PDF
Nearby sections (25 sections)
- cca-201109025 · Common Law Tests
- cca-201109024 · Partnership Item
- cca-201109023 · Notice to Partners of Proceedings
- cca-201109022 · Penalty for Failure to Include Reportable Transaction…
- cca-201109021 · Affected Item
- cca-201109020 · Affected Item
- cca-201109019 · Tax Matters Partner
- cca-201109018 · Authority to Postpone Certain Tax-Related Deadlines by…
- cca-201108036 · Credit of Overpayment Against Any Tax Liability
- cca-201108035 · Tax Matters Partner
- cca-201108034 · Loan/Lease
- cca-201108033 · Request for Interest Netting
- cca-201108032 · Ancillary Consistent Agreements
- cca-201107024 · Exceptions to Notice
- cca-201107023 · Ancillary Consistent Agreements
- cca-201107021 · Notice to Partners of Proceedings
- cca-201107020 · Execution of Waiver on Joint Return
- cca-201107019 · Miscellaneous Issues
- cca-201107018 · BANKRUPTCY CODE CASES
- cca-201107017 · Exception for Small Partnerships
- cca-201107016 · Tax Matters Partner
- cca-201107015 · Tax Treatment Determined At Partnership Level
- cca-201107014 · Levy and Distraint
- cca-201107013 · Limitations on Credit or Refund (Barred v. Not Barred)
- cca-201107011 · Gross Income v. Not Gross Income