Tax matters partner authority does not extend to a Section 6707A penalty

Plain-English summary

An IRS email addressed who may sign a limitations extension involving a Section 6707A penalty. The response stated that a tax matters partner signs only TEFRA statute extensions. A Section 6707A penalty would not fall under TEFRA, so tax matters partner status would not supply signing authority for that extension. The adviser added that a tax matters partner must be a general partner, so the same individual might have authority in another capacity.

Ruling snapshot

• Question: Does a tax matters partner's authority to sign TEFRA statute extensions cover a Section 6707A penalty?
• Outcome: Advice given: no, although the same person might separately be a general partner.
• Key authorities: IRC § 6707A; TEFRA partnership procedures

Full text (IRS public release)

ID: CCA_2020081908321943
UILC: 6221.00-00, 6231.03-00

Number: 202121011
Release Date: 5/28/2021
From: --------------------
Sent: Wednesday, August 19, 2020 8:32:19 AM
To: ----------------------
Cc: -------------------------------------------------------------------
Bcc:
Subject: RE: -------F872 for 6707A Penalty

Hi --------

The TMP only signs TEFRA statute extensions. The section 6707A penalty wouldn’t be
under TEFRA. I note that a TMP must be a general partner so it could be the same
person anyways.

Happy to discuss.

Thanks --

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