CCA 201109026
Tax Matters Partner
ID: CCA_2011020813295037 Number: 201109026
Release Date: 3/4/2011
Office: ---
UILC: 6231.07-00
From: ---
Sent: Tuesday, February 08, 2011 1:30:02 PM
To: ---
Cc: ---
Subject: RE: TEFRA - SOL signature block language question
1. Whether a member (not a member manager) of an LLC in a lower tier can bind the entity for purposes of the statute extensions. I understand that sec. 6231 relates to TMP designation, but can we use the reasoning in Treas. Reg. § 301.6231(a)(7)-2(b)(3) to treat each member as a member manager in a lower tier when there is no managing member?
1. No. A manager under state law must sign for the TMP
Source: view the official PDF
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