Colin P. Murphy - Page 8




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         holding an interest in a partnership through 1 or more                       
         pass-through partners”).  The Commissioner’s duty to give notice             
         under section 6223(a) arises to the extent the Commissioner is               
         furnished with readily available information containing the name,            
         address, and profits interest of a direct or indirect partner in             
         either or both of two ways.  First, the Commissioner may be                  
         furnished the referenced information through the tax return of               
         the partnership under audit.  See sec. 6223(c)(1).  Second, the              
         Commissioner may be furnished the referenced information through             
         a statement that meets the requirements of section                           
         301.6223(c)-1T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.               
         6784 (Mar. 5, 1987).6  See sec. 6223(c)(2); sec.                             
         301.6223(c)-1T(a), Temporary Proced. & Admin. Regs., supra.  In              
         addition to information that is furnished to the Commissioner in             
         these two ways, the Commissioner may use other readily available             
         information possessed by him.  In that vein, the temporary                   
         regulations provide that the Commissioner has no obligation to               






               6 The temporary regulations are effective for the year in              
          issue.  Effective with partnership taxable years beginning on or            
          after Oct. 4, 2001, the Commissioner has final regulations on the           
          subject matter at hand.  See sec. 301.6223(c)-1, Proced. & Admin.           
          Regs.  The relevant provisions of the temporary regulations that            
          are applicable herein are similar to the final regulations.  The            
          temporary regulations applicable herein are similar to the final            
          regulations.                                                                





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