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IRS Recommends Form for Addressing Partner, Partnership Issues

JUN. 21, 2012

ECC 201236029

DATED JUN. 21, 2012
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Citations: ECC 201236029

UILC: 6224.01-02

 

Release Date: 9/7/2012

 

ID: CCA_2012062108383937

 

 

Office: * * *

 

 

From: * * *

 

Sent: Thursday, June 21, 2012 8:38:52 AM

 

To: * * *

 

Cc:

 

Subject: RE: 870PT(AD) versus 870-LT(AD)

 

 

Part II of the Form 870-LT is a separate agreement that is separately executed by both parties as to affected items. It can be used to resolve partner-level defenses to the partnership-level penalty. These defenses are affected items not determined at the partnership level. It can also be used to determine any partner-level penalties based on affected items such at risk or passive loss. By using this Form appeals can resolve all of these issues, so it is appropriate to use it in your case.
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