[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6224(a)-1]

[Page 173]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                               Assessment
 
Sec. 301.6224(a)-1  Participation in administrative proceedings.

    (a) In general. Every partner in the partnership, including an 
indirect partner, has the right to participate in any phase of 
administrative proceedings. However, except as provided in section 6223 
and the regulations thereunder, neither the Internal Revenue Service nor 
the tax matters partner is required to provide notice of any proceeding 
to the partners. Consequently, a partner who wishes, for example, to be 
present during a preliminary discussion between an examining agent and 
the tax matters partner should make special arrangements with the tax 
matters partner to obtain information as to the time and place of the 
discussion. The Internal Revenue Service and the tax matters partner 
will determine the time and place for all administrative proceedings. 
Arrangements will generally not be changed merely for the convenience of 
another partner.
    (b) 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 Sec. 301.6224(a)-1T contained in 26 CFR 
part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50551, Oct. 4, 2001]