Treasury Regulations (26 C.F.R.)
26 CFR § 301.6224(a)-1
Participation in administrative proceedings.
# (a) In general.
Every partner in the partnership, including an indirect partner, has the right to participate in any phase of administrative proceedings. However, except as provided in section 6223 and the regulations thereunder, neither the Internal Revenue Service nor the tax matters partner is required to provide notice of any proceeding to the partners. Consequently, a partner who wishes, for example, to be present during a preliminary discussion between an examining agent and the tax matters partner should make special arrangements with the tax matters partner to obtain information as to the time and place of the discussion. The Internal Revenue Service and the tax matters partner will determine the time and place for all administrative proceedings. Arrangements will generally not be changed merely for the convenience of another partner.
# (b) 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 § 301.6224(a)-1T contained in 26 CFR part 1, revised April 1, 2001.
[T.D. 8965, 66 FR 50551, Oct. 4, 2001]
Source: view the official text
In this part (40 sections)
- 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.
- 301.6226(a)-1 · Principal place of business of partnership.
- 301.6226(b)-1 · 5-percent group.
- 301.6226(e)-1 · Jurisdictional requirement for bringing an action in…
- 301.6226(f)-1 · Scope of judicial review.
- 301.6227-1 · Administrative adjustment request by partnership.
- 301.6227-2 · Determining and accounting for adjustments requested in an…
- 301.6227-3 · Adjustments requested in an administrative adjustment…
- 301.6227(c)-1 · Administrative adjustment request by the tax matters…
- 301.6227(d)-1 · Administrative adjustment request filed on behalf of a…