6225.00-00. Assessments Made Only After Partnership Level Proceedings Are Completed

• Date: 16 August 2024
• Year: 2024
• Record Number: 202433012
• UILC Number: 6225.00-00
• Subject Matter: Assessments Made Only After Partnership Level Proceedings Are Completed

ID:

UILC:

CCA_2024063013412948

6225.00-00

[Third Party Communication:

Date of Communication: Month DD, YYYY]

Number: 202433012

Release Date: 8/16/2024

From: --------------------

Sent: Tuesday, May 21, 2024 1:52:16 PM

To: ------------------------------------------

Cc: -------------------------------------------------

Bcc:

Subject: RE: Question about NAV project and business bad debt deduction

As 301.6225-2(d)(2) states, amended return modification can only take into account

partnership adjustments and partner tax attributes affected by the partnership

adjustments. Whether a partner would be entitled to a bad debt deduction related to

amounts the partner loaned the partnership is not a partnership adjustment or a partner

tax attribute. Therefore, I do not think it can be included as part of amended return

modification. However, if the partner’s 6501/6511 periods are open, the partner could

file an amended return to claim any deduction to which the partner thinks he/she/it is

entitled that is not dependent on an adjustment to a PRI as appears to be the case

here.

If we entered into a closing agreement with the partner, it could also be included in the

closing agreement and could be taken into account during modification under 301.6225-

2(d)(8).

Thanks,

Jenni

Jenni Black (she/her)

Senior Counsel

CC:PA:06

Phone: (202) 317-5216