Extension by Agreement

ID:
UILC:
CCA_2017030108361143
6224.01-01, 6229.02-00
Number: 201710028
Release Date: 3/10/2017
From:
Sent: Wednesday, March 01, 2017 8:36:11 AM
To:
Cc:
Bcc:
Subject: RE: TEFRA Questions
Hi ---,
Your analysis is correct. If the TMP of a TEFRA partnership is an entity, the statute extension is signed by whoever has the authority, under state law, to sign for the TMPentity. If you have any concerns, you could also get statute extensions from the ultimate taxpayers who would be assessed following the conclusion of the partnership proceeding. For settlement agreements with pass-through partners, Treas. Reg.
301.6224(c)-2(b) identifies who signs for the pass-through partner. If the pass-through partner is an LLC, a manager under state law signs for the LLC.
Please let me know if you have any questions.
Thanks,
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