CCA 201206017
Affected Item
ID: CCA_2012011910480337 Number: 201206017
Release Date: 2/10/2012
Office: ---
UILC: 6231.05-00
From: ---
Sent: Thursday, January 19, 2012 10:48:11 AM
To: ---
Cc: ---
Subject: RE: Request for Advice
If you include gain from the sale of a partnership interest in the partner's stat notice while a concurrent TEFRA proceeding is going on for the sale year, we would have to dismiss the issue from the stat notice proceeding as a premature affected item under GAF v. Commissioner, 114 T.C. 519. See also Bausch & Lomb v. Commissioner issued by the Tax Court this week on the same issue.
Source: view the official PDF
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