Partner's Return Must Be Consistent with Partnership Return or Secretary Notified of Inconsistency

ID: CCA_2011052610394337 Number: 201125031
Release Date: 6/24/2011
Office: ---
UILC: 6222.00-00
From: ---
Sent: Thursday, May 26, 2011 10:39:48 AM
To: ---
Cc: ---
Subject: --- AARs
If I understand your facts correctly, the corporate partner reported a $---loss carryforward on its originally filed --- Form 1120. That loss carryforward derived from an untimely --- AAR and not from a --- original Schedule K-1. Since the --- AAR was untimely, it was a nullity. Because the corporate partner filed inconsistently with the --- original Schedule K-1 we can directly assess the inconsistently reported item under section 6222. But we can only do so if the period for assessment is open for ---.
Under your facts it appears that all relevant periods for assessment have expired as to the $---.