Abatements

ID: CCA_2011032214012837 Number: 201116021
Release Date: 4/22/2011
Office: ---
UILC: 6404.00-00
From: ---
Sent: Tuesday, March 22, 2011 2:01:37 PM
To: ---
Cc: ---
Subject: RE: TEFRA Revised inquiry
A TEFRA proceeding is a proceeding of the partners, not the partnership. Under section 6224 all partners may participate. Under Chef's Choice v. Commissioner, the partnership is not a party to a TEFRA proceeding. An examination is not an ad ministerial act justifying interest abatement. Interest abatement, however, is under --- jurisdiction. So they will need to address any further issues arising under section 6404(g) including whether managerial acts can justify abatement.