Other Requests

ID:
UILC:
CCA_2014030508270501
6227.05-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201413007
Release Date: 3/28/2014
From:
Sent: Wednesday, March 05, 2014 8:27:05 AM
To:
Cc:
Bcc:
Subject: FW: 6512(a)(4) Question
Under Maxwell v. Commissioner, 87 T.C. 783 (1986) the court did not have jurisdiction over partnership items except for computational purposes. I.R.C. 6222(c).
Under section 6227(d) the partner is entitled to file a request for administrative adjustment on
Form 8082 within 3 years of the date of the partnership return. I.R.C. 6227(b). If they did not meet these requirements, it is an invalid claim. See Samuelli v. Commisioner, 132T.C.
No.16)(5-18-2009).