CCA 201140024
Partnership Item
ID: CCA_2011092710373737 Number: 201140024
Release Date: 10/7/2011
Office: ---
UILC: 6231.03-00
From: ---
Sent: Tuesday, September 27, 2011 10:37:50 AM
To: ---
Cc: ---
Subject: RE: Background Information and Issuance of Penalty Letters F5471
A failure to file penalty by the partnership would not be a partnership item (defined as an item under subtitle A under 6231(a)(3)) and would not "relate to an adjustment to a partnership item" under section 6221 or section 6226(f). So it would not be determined in a TEFRA partnership proceeding.
Source: view the official PDF
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