Erroneous examination letter did not need reissuance after partnership audit notice
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This page covers one taxpayer's ruling from 2025, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.
Plain-English summary
Chief Counsel was asked whether the IRS needed to reissue Letter 2205-D after a notice of administrative proceeding had already been issued in a centralized partnership audit. The advice said no. Letter 2205-D is not required by statute under the partnership audit rules. An error in that letter therefore did not affect the IRS's ability to issue a final partnership adjustment.
Ruling snapshot
- Question: Must the IRS reissue Letter 2205-D after it has already issued the partnership audit notice?
- Outcome: Advice given, reissuance was unnecessary
- Key authorities: IRC § 6235; centralized partnership audit rules
Full text (IRS public release)
ID: CCA_2025082208101200 [Third Party Communication:
UILC: 6235B.00-00 Date of Communication: Month DD, YYYY]
Number: 202547017
Release Date: 11/21/2025
From: --------------------
Sent: Monday, April 7, 2025 07:06:12 AM
To: ------------------------
Cc: ------------------
Bcc:
Subject: RE: BBA L2205-D Error
Hi ----------,
The Letter 2205-D does not need to be re-issued because, as you pointed out, the NAP has
already been issued. The Letter 2205-D is not statutorily required under BBA and does not
impact the issuance of the FPA. Please let us know if you have further questions.
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