Selection of a tax matters partner by the partnership, the IRS and the courts

Article Abstract:

The adoption of TEFRA highlighted the need for partnerships to assign their respective tax matters partners (TMP) in representing their entities before the Internal Revenue Service and courts. Under the said ruling, TMP must be designated by the partnership before and after filing its tax return or when the TMP's tenure has already lapsed. The rule also provides that US citizens must be given the priority to be designated as TMP over non-US citizens. In cases when a partnership cannot assign its own TMP for certain reasons, the IRS and the courts will be charged with such a responsibility.

Public Finance Activities, Corporate Tax Administration, Corporate taxes, Tax administration, Representations of groups, Group representation (Mathematics)

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Partnership procedure

Article Abstract:

Problems emerge from designating penalties as affected items in a partnership procedure. Characterization as an affected item fails to match procedurally with the identification of a partner's liability. Various determinations that are pertinent to whether a penalty must be levied should be decided at the partnership level. Another difficulty that emerges from designating penalties as affected item is the necessity of two proceedings.

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Selection of a Tax Matters Partner by the Partnership, the IRS, and the Courts

Article Abstract:

A "tax matters partner" has various duties relating to the IRS, taxation and communication between the partnership, the agency and the courts.The article describes how they select or remove the TMP.

United States, Information services

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