IRS CCA: How Adjustments to Basis, Non-Income Items, Affect a Partnership’s Imputed Underpayment Calculation (IRC §6225)

A partnership’s inside basis in its assets is a non-income item and any IRS adjustment to it would be a positive adjustment (as defined in Treasury Regulations Section 301.6225-1(d)(2)) going into the calculation of Imputed Underpayment, while an adjustment to a partner’s outside basis in the partnership would be done outside of the Bipartisan Budget Act of 2015 (Pub. L. No. 114-74), the Chief Counsel’s Office informally advised. In accord with the centralized partnership audit regime established by the BBA, adjustments to partnership-related items that are “money numbers” — items of income, gain, loss, deduction, or credit — ...