Partner

ID: CCA_2009101308595637 Number: 200947052
Release Date: 11/20/2009
Office: ---
UILC: 6231.02-00
From: ---
Sent: Tuesday, October 13, 2009 9:00:01 AM
To: ---
Cc: ---
Subject: RE:
Whoever the agents think they are addressing. But technically only the partners are parties to a TEFRA proceeding which is analogous to a class action proceeding for the partners. But agents frequently refer to the partnership as the taxpayer since that is the return they are focused on and are adjusting.