Tax Matters Partner May Bind Certain Other Partners

ID: CCA_2012032710202237 Number: 201216035
Release Date: 4/20/2012
Office: ---
UILC: 6224.01-05
From: ---
Sent: Tuesday, March 27, 2012 10:20:31 AM
To: ---
Cc: ---
Subject: RE: None
Section 6224(c)(3) authorizes a TMP to bind non-notice partners if he specifically states that he is doing so. Solely for these purposes a "non-notice partner" is a partner with less than a one percent interest in a partnership with more than 100 partners. I.R.C. 6223(b).
If a TMP cannot bind a pass-thru partner, because the pass-thru partner hold a one percent or greater interest, then the TMP cannot bind the indirect partners who hold an interest thought the pass-thru partner. Treas. Reg. 301.6224(c)-1(b).