Tax matters partner: scope of authority and factors in making an effective choice

Article Abstract:

Partnerships should carefully select their tax matter partners (TMP) because TMPs have important roles in unified administrative and judicial proceedings. The methods for designating a TMP are diverse: the partnership may name its TMP for a particular taxable year when the year's tax return is filed; a partnership may designate a TMP after filing the year's tax return by submitting a statement signed by partners representing over 50% of the partnership's interest; or the partnership can have the designated TMP notify the IRS that another TMP has been selected. Default rules will determine a partnership's TMP if the partnership does not select a TMP. The areas in which TMPs have specific responsibilities include audit proceedings, settlement proceedings, and the filing of petitions for the readjustment of partnership items.

Analysis, Tax consultants, Appointments, resignations and dismissals, Administrative responsibility

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No separate notice to partner - even for carryover years

Article Abstract:

The court held in the 'Olson' case that the invalidation of a partnership's tax credit by a partnership-level determination allows the IRS to perform an assessment of an individual partner for tax liability as a result of this partner's share of the credit without releasing a deficiency notice. The court also held that the assessment could take effective over a number of years if the partner had made a carryback or carryforward of any fraction of the credit. Sec 6230(d)(6) provides that the ordinary deficiency and refund procedures are not applicable to underpayments or overpayments that can be attributed to partnership items or affected items. The court described two types of affected items, namely computations adjustments and factual determination adjustments.

Cases, Basis (Taxation), Tax credits, Carryback losses, Carryforward losses, Carryover losses

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Distinguishing costs of cooperation and control in alliances

Article Abstract:

The sources and impact of the cooperation costs incurred in order to work with an alliance partner is examined. It is found that cooperation costs and transaction costs affect the level of time and effort a manager expends on an alliance, supporting the fundamental proposition that the costs of cooperation and control are conceptually and empirically distinct.

United States, Financial management, Management dynamics, Partnerships, Cost Control Techniques, Finance, Company business management, Company financing, Cost control, Cost reduction

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