The TMP must be a general partner, or in the case of an LLC, must be a member-manager. If the partnership does not designate a TMP, the IRS has the authority to appoint one. A partnership is the relationship between two or more who join together to carry on a trade or business. Each partner contributes money, property, labor, or skills, and each expects to share in the profits and losses. A partner can be an individual person, corporation, trust, estate, or another partnership.
All general partners are personally liable for partnership liabilities.
There can be no limited partners in a general partnership. Merely sharing expenses does not necessarily constitute a partnership. They pool their funds to pay for common expenses such as building rent, secretarial services, utilities, supplies, and building maintenance. Each accountant separately bills his or her own clients. This arrangement of sharing expenses is not considered a partnership.