Tax Treatment Determined At Partnership Level

ID: CCA_2011042209110537 Number: 201121016
Release Date: 5/27/2011
Office: ---
UILC: 6221.00-00
From: ---
Sent: Friday, April 22, 2011 9:11:10 AM
To: ---
Cc: ---
Subject: RE: Question - Partnership Delinquency Penalty - Please Answer
Section 6221 provides for a determination at the partnership level for any penalty "which relates to an adjustment to a partnership item." (emphasis supplied).
The failure to file penalty is not based on an adjustment to a partnership item (e.g., an adjustment to partnership income or loss). So it is not determined under the TEFRA partnership procedures pursuant to section 6221.