Notice to Partners of Proceedings 0930048.pdf 208 7/24/2009 200930048 4941.00-00|Excise Taxes on Acts of Self-Dealing

ID: CCA_2009061710194837 Number: 200930047
Release Date: 7/24/2009
Office: ---
UILC: 6223.00-00
From: ---
Sent: Wednesday, June 17, 2009 10:19:50 AM
To: ---
Cc: ---
Subject: RE: Followup with a conversation you had with ---
You don't need to issue NBAPs to an indirect partner if we already sent notice to the pass-thru partner who was required to forward to the notice under section 6223(h). Under section 6223(c)(3) we only have to issue the NBAP to the indirect partner if the indirect partner is identified in accordance with the regulations at least 30 days before the NBAP was issued to the TMP. Treas. Reg. 301.6223(e)-1(b)(ii).
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