Tax Treatment Determined At Partnership Level

ID:
UILC:
CCA_2016020413430807
6221.00-00, 6231.03-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201608014
Release Date: 2/19/2016
From:
Sent: Thursday, February 04, 2016 1:43:08 PM
To:
Cc:
Bcc:
Subject: RE: Super Quick TEFRA question
Hi ---,
Nothing has changed. We may issue an FPAA for the sale year only as the basis of the partnership item sold is a partnership item and the transaction occurred in the sale year.
The fact that the basis of the item was also a partnership item in a previous year does not change this answer. The transaction at issue occurred in sale year.
Thanks,
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