Industry Director Communication – Publicly-Traded Partnerships that Experience a Technical Termination
February 9, 2010
LMSB-04-0210-006
Impacted IRM: 4.51.2
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MEMORANDUM FOR |
INDUSTRY DIRECTORS, LMSB |
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FROM: |
Keith M. Jones /s/ Keith M. Jones |
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SUBJECT: |
Industry Director Communication – Publicly-Traded Partnerships that Experience a Technical Termination |
This memorandum provides notice and direction relating to a publicly-traded partnership that has experienced a technical termination under section 708 of the Internal Revenue Code. Attachments to this memorandum include: procedures for requesting relief, Delegation of Authority for granting relief, and a sample closing agreement documenting the conditions under which relief is granted.
If you have questions, please contact me or Susan Idleman, Senior NRC Analyst, at 214-435-4786 or Susan.M.Idleman@irs.gov or David Lindenbaum, Senior PFTG Analyst, at 202-283-8407 or David.Lindenbaum@irs.gov.
Attachments:
- Procedures for Requesting Relief
- Delegation of Authority for Granting Relief, pdf
- Sample Closing Agreement
cc:
Commissioner, LMSB
Deputy Commissioner, Operations, LMSB
Deputy Commissioner, International, LMSB
Director, Planning, Quality, Analysis & Support, LMSB
Division Counsel, LSMB
Directors, Field Operations, LMSB
Commissioner, SBSE
www.irs.gov
