Page 245 - 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
submitted pursuant to the modification of the amount of an imputed underpayment must be submitted to the Secretary not later than the close of the 270-day period beginning on the date the notice of a proposed partnership adjustment is mailed, unless the 270-day period is extended with the consent of the Secretary.”
 Does the partnership agreement contain provisions that ensure that reviewed year partners (and former partners) bear their appropriate shares of partnership audit expenses?
 Does the partnership agreement contain provisions that ensure that reviewed year partners (and former partners) bear their appropriate shares of the imputed underpayment (including penalties and interest)?
 Does the partnership agreement contain appropriate provisions for the book allocation of the imputed underpayment (including penalties and interest) and expenses of audit?
 Push out election.
 Even if the partnership election is made, the partnership needs full audit provisions for an audit at the partnership level.
 Should the partnership make the push out election?
 How is the push out election approved by the partnership?
 How is the push out election revoked by the partnership?
 The partners should commit to provide the information necessary to enable the partnership to make the push out election.
 What cooperation provisions apply?
 The partnership agreement might require former partners to keep the partnership informed of their current addresses in order to facilitate delivery of the push out schedule.
 The partnership agreement might contain a requirement for reviewed year partners to amend their returns and to pay the
© Terence Floyd Cuff and Jerald David August, 2016
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