Affected Item

ID:
UILC:
CCA_2016030108405707
6231.05-00
Number: 201614034
Release Date: 4/1/2016
From:
Sent: Tuesday, March 01, 2016 8:40:57 AM
To:
Cc:
Bcc:
Subject: RE: TEFRA question
HI ---,
I agree about the disallowance of the capital losses and ordinary losses reported by the partnership being computational adjustments that do not require partner level determinations. This includes any carryovers of those amounts.
I also agree that, if the partnership was determined to be a sham, the professional fees are affected items likely requiring an affected item SND. Bedrosian v. Comm’r, 144 T.C.
152, 159-61 (2015); Domulewicz v. Comm’r, T.C. Memo. 2010-77.
Thanks,
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