Page 198 - 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
amount by which the tax imposed under chapter 1 would increase if the partner’s share of the adjustments described in subsection (a) were taken into account for such taxable year, plus
(B) in the case of any taxable year after the taxable year referred to in subparagraph (A) and before the taxable year referred to in paragraph (1), the amount by which the tax imposed under chapter 1 would increase by reason of the adjustment to tax attributes under
paragraph (3).
Section 6225(b)(3) provides for adjustment of the partner’s tax attributes on account of the pushed out adjustments:
(3) Adjustment of tax attributes. – Any tax attribute which would have been affected if the adjustments described in subsection (a) were taken into account for the taxable year referred to in paragraph (2)(A) shall –
(A) in the case of any taxable year referred to in paragraph (2)(B), be appropriately adjusted for purposes of applying such
paragraph, and
(B) in the case of any subsequent taxable year, be appropriately adjusted.
c. What does the Push Out Statement Say?
The GENERAL EXPLANATION OF TAX LEGISLATION ENACTED IN 2015 (JCS-1-16, March 2016) provides this guidance concerning the push out statement of adjustments to partners:
Information furnished on statement to the Secretary and to partners
The statement furnished to the Secretary and to partners is to include the amounts of and tax attributes of the adjustments allocable to the recipient partner. Under regulatory authority, the Secretary may require the statement to show the amount of the imputed underpayment allocable to the recipient partner. In addition, the statement is to include the name and taxpayer identification number of the recipient partner. The Secretary may require that the statement include such additional information as is necessary or appropriate to carry out the purposes of the provision, such as the address of the recipient partner and the date the statement is mailed.
© Terence Floyd Cuff and Jerald David August, 2016
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