CCA 202002015
Tax Matters Partner
ID:
UILC:
CCA_2019102408511443
6231.07-00
Number: 202002015
Release Date: 1/10/2020
From:
Sent: Thursday, October 24, 2019 8:51:14 AM
To:
Cc:
Bcc:
Subject: RE: Quick Tefra question
No, he does not. A partnership and an LLC taxed as a partnership are the same (there is no TMM, only TMP). If the person was a proper TMP in the year under audit, subsequently disposing of the person’s interest or going from a member-manager to a non-member-manager in a different year has no effect on the TMP designation for the year in which the person was a member-manager. A TMP designation is only terminated as described in 301.6231(a)(7)-1(l).
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Source: view the official PDF
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