CCA 201109023
Notice to Partners of Proceedings
ID: CCA_2011020708303937 Number: 201109023
Release Date: 3/4/2011
Office: ---
UILC: 6223.00-00
From: ---
Sent: Monday, February 07, 2011 8:30:54 AM
To: ---
Cc: ---
Subject: RE: TEFRA Questions
We are auditing the partnership taxable year so it does not matter if a second return changes the reported numbers. To be valid the FPAA only needs to make a final determination of the amount and allocation of partnership items - we only need to be clear in the FPAA as to which starting numbers the adjustments are being made from. But it should not make a difference which numbers we start with since in both cases we are going to arrive at a bottom line number regardless of what number the partnership starts with.
Source: view the official PDF
Nearby sections (25 sections)
- cca-201111010 · Signing of Partnership Returns
- cca-201111009 · Foreign Tax Credit
- cca-201111008 · Levy Procedure
- cca-201111007 · Confidentiality and Disclosure of Returns and Return…
- cca-201111006 · Allocation of Costs to Contract (See Also 451 and 446)
- cca-201111005 · Assignment of Refund Check
- cca-201111001 · Suspension of Statute of Limitations
- cca-201110011 · Periods of Limitation on Suits (Barred v. Not Barred)
- cca-201109027 · Definitions
- cca-201109026 · Tax Matters Partner
- 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