Determination v. No Determination

ID: CCA_2008102808552637 Number: 200851048
Release Date: 12/19/2008
Office: ---
UILC: 1313.01-00
From: ---
Sent: Tuesday, October 28, 2008 8:55:27 AM
To: ---
Cc: ---
Subject: RE: AAR
The only problem with the closing agreement by the partnership through the TMP is that it would be a legal nullity. You might as well get the janitor to sign it. So you would need settlement agreements with the partners themselves or an FPAA in order to have a final determination. Forms 870-PT qualify as closing agreements for this purpose under section 1313(a)(2) since they are executed under authority of section 7121 as reflected in the forms themselves.