Page 185 - The TEFRA Partnership Audit Rules Repeal:

ALI CLE Live Video Webcast / “The TEFRA Partnership Audit Rules Repeal: Partnership and Partner Impacts” June 7, 2016, Jerald David August and Terence Floyd Cuff
 Can the Internal Revenue Service appoint someone else as partnership representative?
 Can the Internal Revenue Service appoint a mass murderer who is serving a life sentence in prison as the partnership representative?
 Do any Constitutional limitations exist on who can serve as the partnership representative?
 What are the fiduciary duties of the partnership representative appointed by the Internal Revenue Service?
 Is a partnership representative appointed by the Internal Revenue Service bound by the instructions of the Internal Revenue Service? Of the partnership? Of the partners?
 Can the partnership remove a partnership representative appointed by the Internal Revenue Service? Under what circumstances?
 Who pays for the partnership representative designated by the Internal Revenue Service to serve as such?
 Can the partners sue a partnership representative appointed by the Internal Revenue Service for breach of fiduciary duties?
 Can the partners sue the Internal Revenue Service for deficiencies of the partnership representative appointed by the Internal Revenue Service?
 Is the partnership representative appointed by the Internal Revenue Service entitled to charge the partnership for expenses of audit?
 Will the Internal Revenue Service simply appoint a partner as partnership representative?
 Will the Internal Revenue Service appoint an Internal Revenue Service agent or official as partnership representative?
 Can the Internal Revenue Service force someone to be a partnership representative?
 If the Internal Revenue Service appoints the partnership representative, how is the audit funded? Can the Internal Revenue Service compel partnership funding of the audit?
© Terence Floyd Cuff and Jerald David August, 2016
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