AICPA to IRS: Adopt Draft Revenue Ruling on Partnership Targeted Allocations 

Published February 18, 2014

Contact: Shirley Twillman, 202-434-4220,

The American Institute of CPAs (AICPA) sent a draft revenue ruling on the use of partnership target allocation methodology to the Internal Revenue Service (IRS) and Department of the Treasury on Feb. 11, 2014 urging that the IRS adopt it in order to eliminate confusion.

In its cover letter, the AICPA said, “We believe guidance on partnership target allocations methodology is necessary because of its widespread use and the misunderstanding of many people that the government has approved this approach by acquiescing in its use.”

Target allocations are a common method used in allocating partnership items of income, gain, loss, deductions and credits among partners of partnerships. While popular, use of this method runs the risk of being inconsistent with the economic effect rules set forth in the Internal Revenue Code.  And because there is not clear guidance in the area, they are frequently misused.

For more information, or to speak with someone about the AICPA’s draft revenue ruling, contact Shirley Twillman at or 202.434.9220.


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