- 26 - Michigan law, a partnership must be renewed after a certain period of time or it will expire. Lichtenstein did not renew DL & Associates' status as a partnership. G. The Modified Injunction Miller had received a copy of the February 1986 Final Consent and Permanent Injunction from Winer. Sometime in late April or early May 1986, Miller read the proposed TEFRA partnership regulations which had been reprinted in the April 17, 1986, issue of the Daily Tax Report, a publication of the Bureau of National Affairs. After reviewing the proposed TEFRA partnership regulations, Miller, on May 6, 1986, wrote to Winer regarding Winer's settlement of his section 7408 injunction case with the United States. Miller also sent copies of this letter to Fieldstone and Davis. In his letter, Miller informed Winer that he believed Winer's settlement of the section 7408 injunction proceeding action was invalid because: (1) Winer had not resigned as TMP in accordance with the proposed TEFRA partnership regulations; and (2) only general partners could be designated as TMP's. It was Miller's belief that certain provisions in the proposed regulations: confirm that what you did in the settlement process is probably invalid and, should the Proposed Regulations be promulgated in the form in which they are proposed, certain additional steps will have to be taken before your resignation as tax matters partner can be effective and before the successor tax matters partner can be properly designated.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011