Final partnership adjustments need not match the proposed notice

Plain-English summary

Chief Counsel advised that adjustments in a final partnership adjustment do not have to match those in the earlier notice of proposed partnership adjustment. The earlier notice contains proposed rather than final adjustments. When the final document is prepared, adjustments may be changed, added, or removed if appropriate. An examining employee may therefore recommend changes before the final partnership adjustment is issued.

Ruling snapshot

• Question: Must the adjustments in a final partnership adjustment match those in the proposed notice?
• Outcome: advice given
• Key authorities: BBA notice and final partnership adjustment procedures; UILC 6231B.00-00

Full text (IRS public release)

 ID:       CCA_2024010513025143             [Third Party Communication:

 UILC:     6231B.00-00                      Date of Communication: Month DD, YYYY]

Number: 202417013
Release Date: 4/26/2024
From: --------------------
Sent: Friday, January 5, 2024 1:02:51 PM
To: -------------------
Cc:
Bcc:
Subject: RE: FPA procedural question


Hi ----------,

The adjustments in the FPA do not have to match the adjustments in the NOPPA. The
NOPPA contains proposed adjustments as opposed to final ones. As such, adjustments
can be changed, added, or removed when the FPA is prepared, if appropriate.
Therefore, there is no issue with you recommending that the adjustments be changed
prior to the issuance of the FPA.

Please let me know if you have any questions.

Thanks,
Jenni

Jenni Black (she/her)
Senior Counsel
CC:PA:06
Phone: (202) 317-5216