Partnership Item

ID:
Office:
UILC:
CCA_2012021008454637
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6231.03-00
Number: 201211013
Release Date: 3/16/2012
From: ---
Sent: Friday, February 10, 2012 8:46:03 AM
To: ---
Cc: ---
Subject: RE: TEFRA issue
Each TEFRA year is a separate cause of action. So we are free to make all arguments in --- even if they are inconsistent with the partnership reporting in ---. Whether the partnership sold the credits to be generated by partnership activities to A as a third party in ---, or agreed in that year to allocate the credits to him as a partner, is a partnership item for --- to the extent the partnership is required to make that determination under subtitle A for that year. Treas. Reg. 301.6231(a)(3)-1(c)(4). It is also a partnership item for --- when the credits became qualified and were taken since both the credits and all underlying factual/legal determinations for that year are partnership items under Treas. Reg.
301.6231(a)(3)-1(b).
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