Blomquist Holdings, LLC, Crestlawn Investors, LLC, Tax Matters Partner  ·  2025-09-17  ·  U.S. Tax Court  ·  pin 220 F.3d at 1255

“Under [s]ection 6226(c), any partner with an interest in the outcome of the proceeding is entitled to participate in an action brought by the TMP or a notice partner, thereby ensuring that all partners may litigate a dispute with the IRS in a single proceeding.”