Timeliness of Claim

ID:
UILC:
CCA_2014081415400001
6511.09-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201438023
Release Date: 9/19/2014
From:
Sent: Thursday, August 14, 2014 3:40:00 PM
To:
Cc:
Bcc:
Subject: RE: TEFRA question
Yes. The Form 872-P extends the partner’s section 6501 period for partnership and affected items. Section 6230(d)(6) was amended in 1997 to allow refund claims for non-computational affected items under normal non-TEFRA refund procedures. Thus, a partner can generally rely on section 6511(c) for non-computational affected items. Generally, only adjustments to partnership items and resulting computational affected items are considered “attributable to” partnership items and, thus, subject to the restrictions of section 6511(g) and 7422(h).