River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 103

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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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