- 88 - 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...)Page: Previous 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 Next
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