Participation in Administrative Proceedings; Waivers; Agreements

ID: CCA_2011030209184537 Number: 201114029
Release Date: 4/8/2011
Office: ---
UILC: 6224.00-00
From: ---
Sent: Wednesday, March 02, 2011 9:18:54 AM
To: ---
Cc: ---
Subject: RE: withholding tax questions
Under section 6224(a) a limited partner has the right to participate in any administrative proceeding relating to partnership items. So they should be notified and have the right to participate even though they cannot bind the partnership to its withholding tax liability. As mentioned previously, only a general partner can bind the partnership entity to an agreement to its withholding tax liability.