Assessment Authority

ID:
UILC:
CCA_2014082111422601
6201.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201438025
Release Date: 9/19/2014
From:
Sent: Thursday, August 21, 2014 11:42:26 AM
To:
Cc:
Bcc:
Subject: RE: Amended 1040X and partner AAR's
Section 6201(a)(1) and Treas. Reg. 301.6201-1(a)(1) allow assessment on any tax shown on a return. This includes any amount on an amended return. Treas. Reg. 301.6211(a)-1(last sentence) and section 6213(g)(1). Section 6213(b)(4) and Treas. Reg. 301.6213-1(b)(3) allow assessment of any amount paid before or after the issuance of a notice of deficiency.
For partner level AAR’s Section 6227(d) provides.

(d) Other requests
If any partner files a request for an administrative adjustment (other than a request described in subsection (c)), the Secretary may— . . .

(2) assess any additional tax that would result from the requested adjustments,
Section 6224(b) allows a partner to waiver any restriction under the
TEFRA procedures.