Does the power of attorney for a partner in a TEFRA partnership need any special language?
A-4a.2. Yes, in the case of taxpayers that invested through a TEFRA partnership. In order for the power of attorney to qualify under Section 6223, the following language must be included under number 3 or number 5 of Form 2848: “The acts authorized by this power of attorney include representation for the purposes of Subchapter C of Chapter 63 of the Internal Revenue Code.” Q-4a.3. If a taxpayer claims eligibility for the zero percent penalty because the taxpayer disclosed the Son of Boss transaction under Announcement 2002-2, must the taxpayer identify on the Notice of Election (Form 13582) all other listed transactions he engaged in? A-4a.3. Yes. See Section 4(a)(5) and Form 13582, Section IV.
Related Questions
- Would it be practical to have my spouse or domestic partner (my named beneficiary) execute the LACERA Special Durable Power of Attorney form?
- Do special rules apply when a partnership or subchapter S corporation contribute to the HSA of a partner or 2% shareholder/employee?
- Does the power of attorney for a partner in a TEFRA partnership need any special language?
