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).
TMP 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.
