Page 205 - 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
the filing of amended returns of reviewed-year partners pursuant to the procedure for modification of an imputed underpayment in section 6225(c)(2).] The partnership may, however, file an administrative adjustment request pursuant to new section 6227, and the partnership may pay any resulting imputed underpayment at the partnership level.
Example
For example, assume that a partnership files its Form 1065 for taxable year 2020 on March 15, 2021. On November 3, 2021, the partnership discovers an omission from income for 2020. The partnership may not issue amended Schedules K-1 to its partners for 2020. However, the partnership may file an administrative adjustment request and pay the underpayment consistently with new section 6227(b)(1) for the partnership taxable year in which the administrative adjustment request is made. In this situation, the partnership does not furnish amended Schedules K-1 to the partners and the partners do not file amended Federal and State income tax returns with respect to the omitted income.257 [257 The partnership that files the administrative adjustment request is not precluded from furnishing under section 6227(b)(2) an adjusted statement (similar to a Schedule K-1) to each reviewed-year partner, who is then required to pay tax attributable to the partnership adjustment (as provided under guidance provided by the Secretary).]
15. Administrative and Collection Procedures Under the Centralized Partnership Audit Regime
a. Notices of proceedings and adjustment.
The Internal Revenue Service can issue three types of important notifications in connection with a partnership audit. The Internal Revenue Service sends these notifications to the partnership representative. The notifications also apply to any proceeding pertaining to an administrative adjustment request filed by a partnership under Sections 6231(a) and 6227.
The notices are: (1) notice of administrative proceeding (audit) initiated at the partnership level; (2) notice of a proposed partnership adjustment resulting from the proceeding; and (3) notice of any final partnership adjustment resulting from the proceeding.
© Terence Floyd Cuff and Jerald David August, 2016
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