The Repeal and Replacement of the TEFRA Partnership Audit Rules
From: ALI-The Practical Tax Lawyer (Winter 2017)
The Bipartisan Budget Act of 2015 made fundamental changes to how the IRS will conduct audits of partnerships. This article by Jerald David August discusses the partnership audit rules prior to and as a result of TEFRA, drafting for three regimes involving IRS audits of partnerships, the partnership “pushout” election, election out of the Budget Act partnership audit rules, procedural issues/judicial review, the need for guidance in the form of interim notices and regulations, and election out of new centralized partnership audit regime.