CCA 200932052
Settlement Agreement
ID: CCA_2009070114484251 Number: 200932052
Release Date: 8/7/2009
Office: ---
UILC: 6224.01-01
From: ---
Sent: Wednesday, July 01, 2009 2:48:55 PM
To: ---
Cc:
Subject: RE: QUESTION ON PARTNER
When you are talking about someone signing for the partnership itself, you generally are not concerned about an entity's status as TMP. What matters is whether or not the individual or entity has the authority to sign for the partnership under relevant state law, and typically that would be a managing general partner. TMP status is for purposes of the TEFRA provisions, and does not necessarily go to who may or may not bind the partnership. (Typically a TMP is a general partner, but it is the status as general partner which would bind the partnership, if state law agrees, not the status as TMP.) I hope that answers your question.
Source: view the official PDF
Nearby sections (25 sections)
- cca-200933036 · Disclosure in Judicial or Administrative Tax…
- cca-200933035 · Definitions
- cca-200933034 · Definition of a Deficiency
- cca-200933033 · Tax Matters Partner
- cca-200933032 · Exception for Small Partnerships
- cca-200933031 · Similar Rules in Certain Cases
- cca-200933030 · Items Cease to Be Partnership Items in Certain Cases
- cca-200933029 · Trade or Business (Deductible v. Not Deductible)
- cca-200933027 · Period of Limitations for Making Assessments
- cca-200932055 · Gross Income v. Not Gross Income
- cca-200932054 · Extension by Agreement
- cca-200932053 · Coordination with Deficiency Proceedings
- cca-200932052 · Settlement Agreement
- cca-200932051 · Partner's Return Must Be Consistent with…
- cca-200932050 · Definition of a Deficiency
- cca-200932049 · Debt v. Equity Issues
- cca-200931058 · Tax Treatment Determined At Partnership Level
- cca-200931057 · Settlement Agreement
- cca-200931056 · Disclosure to Federal Employees for Tax Administration…
- cca-200931055 · Mailing Notice
- cca-200931054 · Affected Item
- cca-200931053 · Special Rules Applicable to Certain Employment Taxes
- cca-200931052 · Notice to Partners of Proceedings
- cca-200931051 · Collection Due Process - Levy
- cca-200931050 · Rules and Regulations