Tax Matters Partner

ID: CCA_2010101813502937 Number: 201044012
Release Date: 11/5/2010
Office: CC:PA
UILC: 6231.07-00
From: Heard William A
Sent: Monday, October 18, 2010 1:50:32 PM
To: Collins Deborah J
Cc: Ransick Mark N; &&TEFRA
Subject: RE: statute extension
A member-manager can be designated as TMP. Treas. Reg. 301.6231(a)(7)-2 defines a membermanager as a member who, alone or together with others, is vested with the continuing exclusive authority to make management decisions necessary to conduct the business. The operating agreement vests in the designated tax matters member the authority to "oversee or handle all matters relating to taxation of the company." This appears to make the member a "member-manager" eligible to be designated as TMP on the partnership return.