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Ezel / IRS Rulings / 201721019
Chief Counsel Advice 201721019 Released May 26, 2017 Advice

Proper partnership tax year is a partnership item

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This page covers one taxpayer's ruling from 2017, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2017
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

In a brief email response to a TEFRA question, Chief Counsel advised that the proper tax year is a partnership item. The message left it to the recipient to decide whether to include the point in an unspecified document or discussion. The release provides no additional facts, analysis, or authorities.

Ruling snapshot

  • Question: Is the proper tax year a partnership item for TEFRA purposes?
  • Outcome: Advice given. Chief Counsel said it is a partnership item.
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2017040514353443
UILC: 6231.03-00

Number: 201721019
Release Date: 5/26/2017
From:
Sent: Wednesday, April 05, 2017 2:35:34 PM
To:
Cc:
Bcc:
Subject: RE: TEFRA question

The proper tax year is a partnership item. It’s up to you whether you put it in there.

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