Skip to content

General education, not advice for your situation.

Carry Forward Learning Start here Intern0 XP

Treasury Regulations · 26 CFR

§ 301.6223(g)-1. Responsibilities of the tax matters partner.

In effect eCFR current as of October 15, 2026

Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

Regulation under 26 U.S.C. § 6223(g)

Cite as 26 CFR § 301.6223(g)-1

At a glance

Read from the text and its source citation. Not part of the regulation.

Status
In the current eCFR
Issued
October 4, 2001 by T.D. 8965
Issued under
26 U.S.C. § 6223(g)
Length
724 words · about 3 min to read
Cross-references
cites 2 Code sections and 5 regulations; cited by 1
(a) Notices described in section 6223(a)—
(1) Notice of beginning of proceeding. Except as otherwise provided in § 301.6223(a)-2, the tax matters partner shall, within 75 days after the Internal Revenue Service mails the notice specified in section 6223(a)(1), forward a copy of that notice to each partner not entitled to notice from the Internal Revenue Service under section 6223. See § 301.6230(e)-1 for information to be furnished to the Internal Revenue Service.
(2) Notice of final partnership administrative adjustment. The tax matters partner shall, within 60 days after the Internal Revenue Service mails the notice specified in section 6223(a)(2), forward a copy of that notice to each partner not entitled to notice from the Internal Revenue Service under section 6223.
(3) Requirement inapplicable in certain cases. The tax matters partner is not required to send notice to a partner if—
(i) Before the expiration of the applicable 75-day or 60-day period the partnership items of that partner have become nonpartnership items (for example, by settlement);
(ii) That partner is an indirect partner and has not been identified to the tax matters partner at least 30 days before the tax matters partner is required to send such notice;
(iii) That partner is treated as a partner solely by virtue of § 301.6231(a)(2)-1;
(iv) That partner was a member of a notice group as of the date on which the notice was mailed to the tax matters partner (see § 301.6223(b)-1(c)(4) for the date on which a partner becomes a member of a notice group);
(v) The notice has already been provided to that partner by another person; or
(vi) The notice is withdrawn by the Internal Revenue Service under § 301.6223(a)-2.
(b) Other notices or information—
(1) In general. The tax matters partner shall furnish to the partners specified in paragraph (b)(2) of this section information with respect to the following—
(i) Closing conference with the examining agent;
(ii) Proposed adjustments, rights of appeal, and requirements for filing of a protest;
(iii) Time and place of any Appeals conference;
(iv) Acceptance by the Internal Revenue Service of any settlement offer;
(v) Consent to the extension of the period of limitations with respect to all partners;
(vi) Filing of a request for administrative adjustment (including a request for substituted return treatment under § 301.6227(c)-1) on behalf of the partnership;
(vii) Filing by the tax matters partner or any other partner of any petition for judicial review under sections 6226 or 6228(a);
(viii) Filing of any appeal with respect to any judicial determination provided for in sections 6226 or 6228(a); and
(ix) Final judicial redetermination.
(2) Partners to be notified. The tax matters partner shall provide information with respect to any action or other matter specified in paragraph (b)(1) of this section to all notice group representatives and all other partners except partners—
(i) Whose partnership items become nonpartnership items before the expiration of the period specified in paragraph (b)(3) of this section for furnishing that information;
(ii) Who are indirect partners and who are not identified to the tax matters partner at least 30 days before the tax matters partner is required to provide the information;
(iii) Who are treated as partners solely by virtue of § 301.6231(a)(2)-1;
(iv) Who are members of a notice group as of the date on which the tax matters partner takes that action or receives information with respect to that matter (see § 301.6223(b)-1(c)(4) for the date on which a partner becomes a member of a notice group); or
(v) Who have already received information with respect to the action or matter from any other person.
(3) Time for furnishing information. The tax matters partner shall furnish information with respect to an action or other matter described in paragraph (b)(1) of this section within 30 days of taking the action or receiving information with respect to that matter.
(c) Effective date. This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6223(g)-1T contained in 26 CFR part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50550, Oct. 4, 2001]

Other regulations under § 6223

Cross-references

Computed from the citations in the text of 26 CFR.

Code sections it cites

Regulations it cites

Cited by 1 other regulation

Amendment history

From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.

  1. Issued by T.D. 8965 (66 FR 50550)

Where it sits in 26 CFR

  1. Subchapter F Procedure and administration
  2. Part 301 Procedure and administration
  3. Subpart ECFR01918753cdbe68b Assessment
  4. In General

Nearby sections