Tax Matters Partner

ID: CCA_2010082009104737 Number: 201042026
Release Date: 10/22/2010
Office: ---
UILC: 6223.05-00
From: ---
Sent: Friday, August 20, 2010 9:10:52 AM
To: ---
Cc: ---
Subject: RE: AC statute
The regulations require the TMP to forward information to the partners (Treas. Reg. 301.6223(g)-1)), but we cannot force him to. He does not have to forward information to partners whose partnership items have converted to nonpartnership items. Treas. Reg. 301.6223(g)-1(b)(2)(i). Technically, the partners who we agree have expired statutes are also no longer parties to the proceeding. See I.R.C.
6226(d)(1)(A)).