Requesting Publicly Traded Partnership Technical Termination Relief
.01 Required information. A request for publicly traded partnership (PTP) technical termination relief must contain the following information:
(1) Name, address, telephone number, and taxpayer identification numbers of the PTP;
(2) A statement that the interests in the partnership are traded on an established securities market within the meaning of I.R.C. §7704(b)(1);
(3) The name, title, address, and telephone number of a person to contact. If the person to contact is an authorized representative of the taxpayer, a properly executed Form 2848, Power of Attorney and Declaration of Representative, must accompany the request;
(4) The location of the taxpayer's tax staff and records;
(5) A brief description of the taxpayer's business operations, including the principal business activity code used by the taxpayer on its last filed return;
(6) The taxable years for which technical termination relief is sought, the last date on which the taxpayer may file (with extensions) timely returns for those years, and, if earlier, the dates on which the taxpayer intends to file the returns; and
(7) The dollar amount of assets reflected on the most recently filed return.
.02 Specific description of the technical termination event. A request for a technical termination relief should concisely:
(1) State the date(s) of the technical termination(s);
(2) Summarizes the events that caused the technical termination(s);
(3) Identify all partners who, directly, or indirectly, held an interest of 5 percent or more in the PTP immediately before or immediately after the technical termination and discuss the tax impact of the technical termination on those partners; and
(4) Describe the availability, organization, and location of the records and other information that substantiate the taxpayer's request for technical termination relief.
.03 Perjury statement. A request for technical termination relief and any supplemental submissions (including additional documents), must include a declaration, signed by a person currently authorized to sign the taxpayer's federal income tax return, in the following form:
Under penalties of perjury, I declare that I have examined this request, including accompanying documents, and to the best of my knowledge and belief, the facts presented in support of the request for technical termination relief are true, correct, and complete.
.04 Where to submit relief requests. Interested parties should submit relief requests by e-mail to *firstname.lastname@example.org. Alternatively, requests can be mailed or faxed to:
Internal Revenue Service
Office of PreFiling and Technical Services
Large Business and International Division LM:PFTG
Mint Building 3rd Floor M3-352
1111 Constitution Avenue NW
Washington, DC 20224