CCA 202246010
Tax Matters Partner
ID:
UILC:
CCA_2022070607383043
6231.07-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 202246010
Release Date: 11/18/2022
From: ---
Sent: Wednesday, July 6, 2022 7:38:30 AM
To: ---
Cc:
Bcc:
Subject: RE: TEFRA TMP Question
A TMP is designated on the partnership return, not in the operating agreement. So long as the person designated on the return is eligible to be TMP (e.g,. they are a member of the partnership and have management control over the partnership – see 301.6231(a)(7)-1 and -2) then that person is TMP. If you have any more questions my calendar is up to date so please feel free to pick a time that is convenient for you.
Thanks,
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Source: view the official PDF
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