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Industry Director Communication – Publicly-Traded Partnerships that Experience a Technical Termination

February 9, 2010

LMSB-04-0210-006
Impacted IRM: 4.51.2
 

 

MEMORANDUM FOR

INDUSTRY DIRECTORS, LMSB
DIRECTOR, FIELD SPECIALISTS, LMSB
DIRECTOR, INTERNATIONAL COMPLIANCE, STRATEGY AND POLICY
DIRECTOR, PRE-FILING AND TECHNICAL GUIDANCE, LMSB
DIRECTORS, FIELD OPERATIONS, NATURAL RESOURCES AND CONSTRUCTION

FROM:

Keith M. Jones /s/ Keith M. Jones
Industry Director
Natural Resources and Construction

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  or David Lindenbaum, Senior PFTG Analyst, at 202-283-8407.

Attachments:

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                    

Page Last Reviewed or Updated: 05-Sep-2013