Use of Information in Judicial or Administrative Nontax Proceedings

ID:
UILC:
CCA_2015010914091301
6103.09-03
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201509032
Release Date: 2/27/2015
From:
Sent: Friday, January 09, 2015 2:09:13 PM
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Cc:
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Subject: RE: TEFRA/disclosure question
Each year is a separate cause of action . Because of this we require separate FPAA’s for each year when the partners are not the same in order to avoid disclosure issues.
But you are probably O.K. under section 6103(h)(4)(B) since the year 1 resolution conclusively establishes year 2 treatment.