Tax Matters Partner

ID:
UILC:
CCA_2016021108252507
6231.07-00
Number: 201620010
Release Date: 5/13/2016
From: ---
Sent: Thursday, February 11, 2016 8:25:25 AM
To: ---
Cc: ---
Bcc:
Subject: RE: Question about TMP
Hi ---,
If --- is the TMP and --- is the person legally authorized to sign on behalf of ---, he may sign the statute extension despite the fact of ------ . The TMP is the LLC. Only a general partner (or member manager) may be a TMP. That is a state law concept. The fact that --- is disregarded under federal tax laws cannot change state agency law and convert the owner of a DE into a general partner with power under state law to bind other partners.
Please let me know if you have any questions or if I can be of any further assistance.
Thanks,
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