- 9 -
for the sole purpose of permitting them to file a petition with
the Tax Court in this case.
1. General Discussion
The TMP is the central figure of partnership proceedings,
and, consequently, his status is of critical importance to the
proper functioning of the partnership audit and litigation
procedures. He serves as the focal point for service of all
notices, documents, and orders for the partnership in both
administrative and judicial proceedings. See Computer Programs
Lambda, Ltd. v. Commissioner, 89 T.C. 198, 205-206 (1987). As
the result of his statutory responsibilities, the TMP acts as a
fiduciary, and, as a fiduciary, his actions affect the rights of
all partners in the partnership. See id. at 205-206.
The TMP may extend the period of limitations with respect to
all partners in a partnership by an agreement between the IRS and
the TMP, or the period may be extended by an agreement between
the IRS and any other person authorized by the partnership in
writing.9 See sec. 6229(b)(1)(B).
9 The period of limitations for a specific partner may also be
extended by an agreement between the IRS and that partner. See
sec. 6229(b)(1)(A).
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