Tax Treatment Determined At Partnership Level

ID:
Office:
UILC:
CCA_2011121411441037
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6221.00-00
Number: 201202023
Release Date: 1/13/2012
From: ---
Sent: Wednesday, December 14, 2011 11:44:29 AM
To: ---
Cc: ---
Subject: RE: Statute Extension Question
You don't need to open a TEFRA proceeding or keep the statute open at the partnership level in order to determine a partner's affected items such as the partner-level worthlessness loss. You only need to get a Form 872 from the partner (current version that also relates to affected items). For the purposes of the partner-level audit, however, you will be bound by how the partnership reported its items and reflected them in its books and records. See Roberts v. Commissioner, 94 T.C. 853 at 860. You can solicit the information directly from the partner, or from the partnership for purposes of the partner-level audit.
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