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In pertinent part, section 301.6231(a)(7)-1T(a), Temporary
Proced. & Admin. Regs., 52 Fed. Reg. 6791 (Mar. 5, 1987),
provides: “A partnership may designate a partner as its tax
matters partner for a specific taxable year only as provided in
this section.”
Section 301.6231(a)(7)-1T(b)(1), Temporary Proced. & Admin.
Regs., supra, provides the following general requirement:
A person may be designated as the tax matters partners
of a partnership for a taxable year only if that person
--
(i) Was a general partner in the partnership at
some time during the taxable year for which the
designation is made, or
(ii) Is a general partner in the partnership as of
the time the designation is made.
Section 301.6231(a)(7)-1T(e), Temporary Proced. & Admin.
Regs., supra, provides:
Designation by general partners with majority
interest. The partnership may designate a tax matters
partner for a partnership taxable year at any time
after the filing of a partnership return for that
taxable year by filing a statement with the service
center with which the partnership return was filed. The
statement shall--
(1) Identify the partnership and the designated
partner by name, address, and taxpayer identification
number,
(2) Specify the partnership taxable year to which
the designation relates,
(3) Declare that it is a designation of a tax
matters partner for the taxable year specified, and
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