Manner of Electing Optional Adjustment to Basis of Partnership Property

ID:
UILC:
CCA_2023050114211948
754.00-00, 741.00-00, 6221.00-
00, 6241.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 202346016
Release Date: 11/17/2023
From: ---
Sent: Monday, May 1, 2023 2:21:19 PM
To: ---
Cc: ---
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Bcc:
Subject: RE: 2023 Case Study - Ready for Counsel Review
Hi ---,
Attached please find our comments to the slides and the factual summary document. Our main concern is that the example appears to be assessing tax on the partners as a result of the adjustments made in the BBA exam after the partnership pays the IU. Generally when the partnership pays the IU, if a partner level tax results because of the PRI adjustments, the Service cannot assess/collect against the partner for that tax.
We think it may be helpful to schedule a call discuss our comments, and I am happy to set up a call at a time / day convenient for you. Thank you!
Kind regards,
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