Tax Matters Partner

ID:
Office:
UILC:
CCA_2009081414115537
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6231.07-00
Number: 200940024
Release Date: 10/2/2009
From: ---
Sent: Friday, August 14, 2009 2:11:58 PM
To: ---
Cc: ---
Subject: RE: tax matters partner determination question
I agree that there was no valid designation of TMP since a limited partner (and its indirect partner manager) are not eligible under section 6231(a)(7). Treas. Reg. 301.6231(a)(7)-1(b). Under Treas. Reg.
301.6231(a)(7)-1(m)(2) we can rely on the Schedules K-1 to determine the general partner with the largest profits interest for the year in issue, and, thus, the default TMP under section 6231(a)(7)(B).
We don't need a TMP to issue an FPAA since a generic TMP FPAA is sufficient under Treas.
Reg.301.6223(a)-1.
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