In the case of a TMP
under criminal tax investigation, TMP
status does not terminate under the regulations until the IRS sends him the "-5T notice" (Regs.
If a partnership return has previously been filed (and a TMP
selected), a successor TMP
can be chosen by having the current TMP
so certify in a statement sent to the service center where the partnership return is filed (Regs.
At the completion of the audit, the IRS must notify the TMP
and notice partners of the resulting final partnership administrative adjustment (FPAA).
does not generally elevate potassium concentrations to harmful levels.
Amended return by non-TMP
partner: A partner other than the TMP
may also file an AAR with respect to his partnership by using generally the same procedures as the TMP
Literally, this appears to be a different right relating to acceleration of the maturity of the second class, which could result in the trust being a TMP
The designated TMP
must be a person who is a general partner in the partnership at some time during the tax year for which the designation is made.