Agri-Cal Venture Associates, Frederick H. Behrens, Tax Matters Partner, et al. - Page 29




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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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