Assessments Made Only After Partnership Level Proceedings Are Completed

ID:
UILC:
CCA_2014042409285901
6225.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201419014
Release Date: 5/9/2014
From:
Sent: Thursday, April 24, 2014 9:28:59 AM
To:
Cc:
Bcc:
Subject: RE: TEFRA carryforwards
Sections 6221 requires a partnership item to be determined at the partnership level. Section 6201 and 6225 say we can assess the partnership item after it is determined through an FPAA. The --- partnership item that was claimed on the partner return for --- was disallowed in the --- FPAA. So we can assess. Seems pretty straight forward. The analysis is scant for that reason. It doesn’t matter which return the partner claims the --- partnership item on. It still has to be determined at the partnership level before we can assess it.