RULE 247. PARTIES
- (a) In General: For purposes of this title of these Rules,
the Commissioner, the partner who filed the petition, the tax
matters partner, and each person who satisfies the requirements of
Code section 6226(c) and (d) or 6228(a)(4) shall be treated as
parties to the action.
- (b) Participating Partners: Participating partners are the
partner who filed the petition and such other partners who have
filed either a notice of election to intervene or a notice of
election to participate in accordance with the provisions of Rule 245. See Code Sections 6226(c) and
6228(a)(4)(A).
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