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designation of a TMP remains effective until the termination of
that designation pursuant to section 301.6231(a)(7)-1(1)T,
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6792 (Mar. 5,
1987), which provides in pertinent part:
(l) Termination of designation. A designation of a
tax matters partner for a taxable year under this
section shall remain in effect until–
* * * * * * *
(4) The partnership items of the tax matters partner
become nonpartnership items under section 6231(c)
(relating to special enforcement areas), * * *
* * * * * * *
The termination of the designation of a partner as the
tax matters partner under this paragraph (l) does not
affect the validity of any action taken by that partner
as tax matters partner before the designation is
terminated. For example, if that tax matters partner
had previously consented to an extension of the period
for assessments under section 6229(b)(1)(B), that
extension remains valid even after termination of the
designation.
In turn, section 6231(c), relating to special enforcement areas,
applies to criminal investigations that the Secretary determines
by regulation to present special enforcement considerations.
Section 301.6231(c)-5T, Temporary Proced. & Admin. Regs., 52
Fed. Reg. 6793 (Mar. 5, 1987),20 was promulgated by the Secretary
19(...continued)
1, Proced. & Admin. Regs., which is effective for all
designations, selections, and terminations of a TMP occurring on
or after Dec. 23, 1996. See sec. 301.6231(a)(7)-1(s), Proced. &
Admin. Regs.
20 This temporary regulation concerning criminal tax
(continued...)
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