Extension by Agreement

ID: CCA_2010083116025337 Number: 201039031
Release Date: 10/1/2010
Office: ---
UILC: 6229.02-00
From: ---
Sent: Tuesday, August 31, 2010 4:02:57 PM
To: ---
Cc: ---
Subject: RE: TEFRA Extension - who can sign
We do not assess flow through entities. In a TEFRA proceeding we only assess the partners, not the partnership. Thus a Form 872 will always reflect the taxpayer (the partner) we are actually assessing.
This is different from a Form 872-P which reflects the partnership name. But even in the case of a Form 872-P we do not assess the partnership - that form extends the period for assessing all partners.