Authority of Tax Matters Partner. The TMP shall have the authority to take any and all action reasonably required as TMP, including by way of example, any of the following: (i) enter into a settlement agreement with the Internal Revenue Service that purports to bind the Partners other than the TMP; (ii) file a Tax Court Petition as contemplated in Code Section 6226(a) or Section 6228; (iii) intervene in any action as contemplated in Code Section 6226(b); (iv) file any requests for administrative adjustment contemplated in Code Section 6227(b); or (v) enter into an agreement extending the limitations period as contemplated by Code Section 6229(b)(1)(B).
Authority of Tax Matters Partner. The Tax Matters Partner is hereby authorized, but not required:
Authority of Tax Matters Partner. The TMP shall have the -------------------------------- full authority to take any and all actions otherwise permitted to be taken by a tax matters partner under the Code in connection with any audit, examination or investigation of the Partnership, and in connection with any and all administrative and judicial proceedings arising out of such audit, examination or investigation, including, but not limited to, any of the following actions:
Authority of Tax Matters Partner. Without the consent of the other General Partner, the Tax Matters Partner shall not:
Authority of Tax Matters Partner. The Tax Matters Partner is hereby authorized, but not required: (a) To enter into any settlement with the Internal Revenue Service or the Secretary with respect to any tax audit or judicial review, in which agreement the Tax Matters Partner may expressly state that such agreement shall bind the other Members, except that such settlement agreement shall not bind any Member who (within the time prescribed pursuant to the Code and Treasury Regulations thereunder) files a statement with the Secretary providing that the Tax Matters Partner shall not have the authority to enter into a settlement agreement on behalf of such Member; (b) In the event that a notice of a final administrative adjustment at the Company level of any item required to be taken into account by a Member for tax purposes (a “final” adjustment”) is mailed to the Tax Matters Partner, to seek judicial review of such final adjustment, including the filing of a petition for readjustment with the Tax Court, the District Court of the United States for the district in which the Company’s principal place of business is located, or the United States Court of Claims; (c) To intervene in any action brought by any other Member for judicial review of a final adjustment; (d) To file a request for an administrative adjustment with the Secretary at any time and, if any part of such request is not allowed by the Secretary, to file a petition for judicial review with respect to such request; (e) To enter into an agreement with the Internal Revenue Service to extend the period for assessing any tax which is attributable to any item required to be taken into account by a Member for tax purposes, or an item affected by such item;
Authority of Tax Matters Partner. (a) The Tax Matters Partner shall have and perform all of the duties required under the Code, including the following:
Authority of Tax Matters Partner. The Tax Matters Partner is hereby authorized to do the following:
Authority of Tax Matters Partner. The TMP shall have the authority to take any and all action reasonably required as TMP, including by way of example, any of the following: (i) enter into a settlement agreement with the Internal Revenue Service that purports to bind the Partners other than the TMP; (ii) file a Tax Court Petition as contemplated in Code Section 6226(a) or Section 6228; (iii) intervene in any action as contemplated in Code Section 6226(b); (iv) file any requests for administrative adjustment contemplated in Code Outback Catering Company-II, Limited Partnership 9 Section 6227(b); or (v) enter into an agreement extending the limitations period as contemplated by Code Section 6229(b)(1)(B).
Authority of Tax Matters Partner. The Tax Matters Partner may, in its sole discretion:
