Treasury Regulations (26 C.F.R.)
26 CFR § 301.6223(a)-1
Notice sent to tax matters partner.
# (a) In general.
For purposes of subchapter C of chapter 63 of the Internal Revenue Code, a notice is treated as mailed to the tax matters partner on the earlier of—
(1) The date on which the notice is mailed to “THE TAX MATTERS PARTNER” at the address of the partnership (as provided on the partnership return, except as updated under § 301.6223(c)-1); or
(2) The date on which the notice is mailed to the person who is the tax matters partner at the address of that person (as provided on the partner's return, except as updated under § 301.6223(c)-1) or the partnership. See § 301.6223(c)-1 for rules relating to the information used by the Internal Revenue Service in providing notices, etc.
# (b) Example.
The provisions of this section may be illustrated by the following example:
Example.
Partnership P designates B as its tax matters partner in accordance with § 301.6231(a)(7)-1(b). On December 1 a notice of the beginning of an administrative proceeding is mailed to “THE TAX MATTERS PARTNER” at the address of P. On January 10, a copy of the notice is mailed to B at B's address. December 1 is treated as the date that the notice was mailed to the tax matters partner.
# (c) Effective date.
This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6223(a)-1T contained in 26 CFR part 1, revised April 1, 2001.
[T.D. 8965, 66 FR 50547, Oct. 4, 2001]
Source: view the official text
In this part (40 sections)
- 301.6203-1 · Method of assessment.
- 301.6204-1 · Supplemental assessments.
- 301.6205-1 · Special rules applicable to certain employment taxes.
- 301.6211-1 · Deficiency defined.
- 301.6212-1 · Notice of deficiency.
- 301.6212-2 · Definition of last known address.
- 301.6213-1 · Restrictions applicable to deficiencies; petition to Tax…
- 301.6213-2 · Omission of correct vehicle identification number.
- 301.6215-1 · Assessment of deficiency found by Tax Court.
- 301.6221-1 · Tax treatment determined at partnership level.
- 301.6221(a)-1 · Determination at partnership level.
- 301.6221(b)-1 · Election out for certain partnerships with 100 or fewer…
- 301.6222-1 · Partner's return must be consistent with partnership…
- 301.6222(a)-1 · Consistent treatment of partnership items.
- 301.6222(a)-2 · Application of consistent reporting and notification…
- 301.6222(b)-1 · Notification to the Internal Revenue Service when…
- 301.6222(b)-2 · Effect of notification of inconsistent treatment.
- 301.6222(b)-3 · Partner receiving incorrect schedule.
- 301.6223-1 · Partnership representative.
- 301.6223-2 · Binding effect of actions of the partnership and…
- 301.6223(a)-1 · Notice sent to tax matters partner.
- 301.6223(a)-2 · Withdrawal of notice of the beginning of an…
- 301.6223(b)-1 · Notice group.
- 301.6223(c)-1 · Additional information regarding partners furnished to…
- 301.6223(e)-1 · Effect of Internal Revenue Service's failure to provide…
- 301.6223(e)-2 · Elections if Internal Revenue Service fails to provide…
- 301.6223(f)-1 · Duplicate copy of final partnership administrative…
- 301.6223(g)-1 · Responsibilities of the tax matters partner.
- 301.6223(h)-1 · Responsibilities of pass-thru partner.
- 301.6224(a)-1 · Participation in administrative proceedings.
- 301.6224(b)-1 · Partner may waive rights.
- 301.6224(c)-1 · Tax matters partner may bind nonnotice partners.
- 301.6224(c)-2 · Pass-thru partner binds indirect partners.
- 301.6224(c)-3 · Consistent settlements.
- 301.6225-1 · Partnership adjustment by the Internal Revenue Service.
- 301.6225-2 · Modification of imputed underpayment.
- 301.6225-3 · Treatment of partnership adjustments that do not result in…
- 301.6226-1 · Election for an alternative to the payment of the imputed…
- 301.6226-2 · Statements furnished to partners and filed with the IRS.
- 301.6226-3 · Adjustments taken into account by partners.