Extension by Agreement

ID:
UILC:
CCA_2013112209201201
6229.02-00
Third Party Communication: None
Date of Communication: Not Applicable
Number: 201402011
Release Date: 1/10/2014
From:
Sent: Friday, November 22, 2013 9:20:13 AM
To:
Cc:
Bcc:
Subject: RE: TEFRA question
The carryforward amount of any adjustment is a computational affected item under Olsen v. U.S., 172 F.3d 1311 (Fed. Cir. 1999);
Cummings v. Commissioner, T.C. Memo 1996-282; Bob Hambric
Chevrolet v. U.S., 849 F. Supp. 500 (WD Tex. 1994).
When the TMP signs a Form 872-P, he extends the minimum period for assessment any tax attributable to a disallowed partnership loss, regardless of which return a partner claimed that loss on. So when he extends the period for assessing tax “attributable to” a partnership loss for partnership year 1, he is extending the assessment period for all partner returns claiming that loss including carryforward years.
There is nothing in the Form 872-P that limits the assessment to a partner return for year 1.