Tax matters partner must sign earlier-year extensions

Plain-English summary

Chief Counsel addressed who may sign Form 921-P for earlier partnership tax years. If the named person is the tax matters partner for those years, she may sign. Otherwise, the earlier years' tax matters partner must sign unless the partnership gives her written authority to sign the consent.

Ruling snapshot

• Question: Who may sign Form 921-P to extend the period for earlier partnership tax years?
• Outcome: advice given
• Key authorities: IRC § 6231; Form 921-P instructions

Full text (IRS public release)

ID: CCA_2016100612570315
UILC: 6231.07-00

Number: 201652019
Release Date: 12/23/2016
From:
Sent: Thursday, October 06, 2016 12:57:03 PM
To:
Cc:
Bcc:
Subject: RE TEFRA Statute Extension for Rev. Proc. 92-29 Project Questions

John,

If, in your example, Jane Smith is now the TMP for the earlier tax years, she may sign
the Form 921-P for those years. If she is not, then the TMP for the earlier years will
need to sign Forms 921-P unless the partnership provides written authorization for Jane
Smith to sign a consent for those years. See the instructions on the reverse side of the
Form 921-P.

Samuel Berman
Special Counsel
Office of Division Counsel
(Small Business/Self-Employed)
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