Tax Matters Partner

ID: CCA_2012040414392737 Number: 201219023
Release Date: 5/11/2012
Office: ---
UILC: 6231.07-00
From: ---
Sent: Wednesday, April 04, 2012 2:39:42 PM
To: ---
Cc: ---
Subject: RE: TMP designation on amended 1065; send FPAA to terminated TMP?

(1) No. A TMP designation cannot be made on an amended return since that does not comply with the regulation under 6231(a)(7).

(2) Generally, in the absence of a new designation, the largest profits interest general partner becomes TMP by operation of law under section 6231(a)(7)(B). No partnership or service designation need occur.

(3) In any event, a generic TMP notice under Treas. Reg. 301.6223(a)-1 satisfies our requirement to send an FPAA to the TMP regardless of whether a notice is sent to a named TMP.