Miscellaneous Issues

ID:
UILC:
CCA_2022070113172307
9999.00-00
Third Party Communication: None
Date of Communication: Not Applicable
Number: 202241006
Release Date: 10/14/2022
From: ---
Sent: Friday, July 1, 2022 1:17:23 PM
To: ---
Cc:
Bcc:
Subject: Request for Advice
This email responds to your request for advice regarding a position ---
--- took on its tax return for the --- and --- tax years. Exam is evaluating whether to make an adjustment to taxpayer’s --- return.
This issue had been analyzed and extensively coordinated by the time taxpayer took its position on its returns for the --- and --- tax years, so FIP was familiar with this issue when we learned of this proposed adjustment. Given the many challenges with this issue, a conclusion was reached during the prior coordination that guidance would have had to have been provided to ensure similarly situated taxpayers were not treated differently. That is, the result reached during the prior coordination was that regulations would have been necessary to support an adjustment to taxpayer’s return. A fully coordinated decision was previously made not to propose such regulations.
Accordingly, FIP does not support making an adjustment to the taxpayer’s return with respect to this issue.