IRS Addresses Partnership Reportable Transactions Penalties

UILC:6221.00-00, 6231.03-00
Release Date: 5/28/2021

ID:CCA_2020081908321943

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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