Affected Item

ID:
UILC:
CCA_2019110508450043
6231.03-00, 6231.05-00
Number: 202020001
Release Date: 5/15/2020
From:
Sent: Tuesday, November 05, 2019 8:45:00 AM
To:
Cc:
Bcc:
Subject: RE: ---Review of Basis Computation - Captial Contribution Question
Good morning,
Sorry, I am just now getting to this. I was out of the office last week and I spent most of yesterday catching up. The partner’s outside basis in his/her partnership interest is an affected item. You may adjust an affected item at the partner level without opening a partnership-level examination if you accept the partnership return as filed. See Meruelo v. Comm’r, 691 F.3d 1108 (9th Cir. 2012); Roberts v. Comm’r, 94 T.C. 853 (1990). In adjusting outside basis at the partner level in this manner, you cannot change any of the partnership-item components of outside basis without opening a TEFRA proceeding.
You can adjust the overall computation of outside basis (again, accepting all the partnership item components as filed on the partnership return) and any nonpartnership-item components of outside basis. Please let me know if you have any questions.
Thanks,
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