6231(c)-5T, the IRS argued that it had sole discretion as to whether and when to remove a TMP
because of a criminal tax investigation.
expects a number of notable events to take place on TMP
Island throughout 2007, beginning in the first half of the year.
A partnership may designate a TMP
after filing the partnership return for a tax year by submitting a statement signed by general partners who held more than 50% of the aggregate interest in partnership profits held by all general partners at the close of the tax year.
As a practical matter, he has little incentive to deny the TMP
the right to enter into a settlement agreement, since he would be offered an administrative settlement consistent with that offered to the other partners.
As a result, in every case in which the AAR is expected to result in a net reduction in tax to the affected partners, the TMP
or other partner filing the AAR should always monitor the two-year period to ensure that, if necessary to secure the desired changes in the amended return, either a petition is filed before the two-year period runs or, alternatively, an extension is executed.
rules will also apply to previously existing entities that receive "a substantial transfer of cash or other property" after 1991, beginning on the day of that substantial transfer.
Note: The TMP
must be a partner in the partnership.
NEW YORK -- TMP
Worldwide Directional Marketing was recently honored for Yellow Pages advertising innovation and creativity at the 2004 Industry Excellence Awards sponsored by the Yellow Pages Association(TM) (YPA).
The new facility, which began rolling out products last December, occupies 11,000 square meters and is located adjacent to Spansion (China) Limited's existing Flash memory assembly and TMP
Having Earl Greenburg and TMP
team working with CirTran in an industry they helped found and define should put CirTran in a favorable position to build our business in this lucrative and fast-growing market sector," said Trevor M.
com, the largest and most up-to-date free business directory information service in America, today announced that it has entered into an exclusive agreement with TMP
Worldwide Directional Marketing, the world's largest Yellow Page advertising agency and a division of Monster Worldwide, for the sales and marketing of its telephone advertising space.
As the honorary chairpersons, Black, Jimenez and the Knowles family will help to support music education throughout Texas by lending time and talent to TMP