IRS Letter 1830: Final Partnership Administrative Adjustment (FPAA)

What This Letter Means

Letter 1830 is the cover letter for a Notice of Final Partnership Administrative Adjustment, called an FPAA. It ends the IRS audit of a partnership under the TEFRA rules and states the adjustments the IRS is making to the partnership's items for one tax year.

TEFRA governs partnership tax years that began before 2018. Partnership years beginning after December 31, 2017 fall under the newer centralized audit regime, which uses different notices. If you get a Letter 1830, it concerns an older year.

Who Gets It

The IRS mails the FPAA to the tax matters partner, both by name and by title at the partnership's address, and to each notice partner. A complete FPAA package includes Letter 1830, the agreement form (Form 870-PT) with its Schedule of Adjustments, and an Explanation of Adjustments. Each Letter 1830 covers only one tax year.

The Deadlines

• Tax matters partner: 90 days after the FPAA is mailed to file a petition for readjustment in the U.S. Tax Court, the U.S. Court of Federal Claims, or the federal district court where the partnership has its principal place of business.
• Other partners: if the tax matters partner does not file, any notice partner, or a group of partners holding 5 percent or more of the profits interest, can file within 60 days after the 90-day period ends.

Every person who was a partner during the year is treated as a party to the case, whoever files it. The tax matters partner and pass-thru partners must forward the FPAA to partners who did not get it directly. A claim that you never saw the FPAA generally won't save you.

Why This Matters

This is the partnership's day in court. You generally can't challenge partnership items later in a Collection Due Process hearing, because the partnership proceeding was your opportunity. Once the deadlines pass, the adjustments flow through to each partner's own return.

What to Do

• Note the mailing date and count 90 days. Count the extra 60 days if you are a notice partner.
• Read the Explanation of Adjustments and the Schedule of Adjustments line by line.
• If you are the tax matters partner, tell the other partners right away.
• Don't sign Form 870-PT until you understand that it settles the year.
• Talk to a tax litigator before the deadline. Choosing the court is a strategic decision.

If you received a Letter 1830 FPAA and need to protect the partnership's right to go to court, call us at (813) 229-7100.