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requirement of section 301.6231(a)(7)-1T(e), Temporary Proced. &
Admin. Regs., 52 Fed. Reg. 6778 (Mar. 5, 1987), was substantially
complied with when the September 30 letter was received in hand
by Deborah Gaither, respondent’s revenue agent, and that all
requirements of the regulation have been satisfied. The
September 30 letter was effective to designate George L.
Schreiber the TMP of the partnership.
d. Timeliness of Designation
AVA argues that, even if the September 30 letter was
effective to designate Mr. Schreiber as the TMP of the
partnership, the September 30 letter was not filed by respondent
before Mr. Schreiber signed the AVA Form 872-P for 1985, which
was signed on September 30, 1988. It is true that the
September 30 letter is stamped received, Laguna Niguel District,
with a date of October 4, 1988. Nevertheless, we have found that
the September 30 letter was received in hand by one of
respondent’s revenue agents on September 30, 1988, and such
receipt substantially complied with section 301.6231(a)(7)-1T(e),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6792 (Mar. 5,
1987). In pertinent part, section 301.6231(a)(7)-1T(k),
Temporary Proced. & Admin. Regs., provides that a statement
designating a TMP becomes effective on the day the statement is
filed. Generally, the filing of a paper takes place upon the
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