Page 248 - 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
 What are the qualifications of the partnership representative?
 Must the partnership representative be a partner?
 What is the term of the partnership representative?
 How is the partnership representative selected?
 How is the partnership representative removed?
 For what reasons can the partnership representative be removed?
 Is removal limited to “cause”? What is “cause”?
 Should the partnership have the absolute right to
remove the partnership representative?
 Can the partnership representative resign?
 What is the resignation procedure?
 How does the partnership select a replacement partnership representative?
 What are the fiduciary duties of the partnership representative? These might include duty of care and loyalty. It also may include a duty of confidentiality.
 What are the duties of the partnership representative? These duties might include:
 To undertake the partnership audit, using the partnership accountants and counsel.
 To undertake litigation on behalf of the partnership in the United States Tax Court, District Court, or Court of Federal Claims.
 To copy the partnership on all notices and other correspondence from the Internal Revenue Service?
 To consult with partnership management concerning audit strategy?
 To represent the partnership in audits in accordance with agreed audit strategy?
© Terence Floyd Cuff and Jerald David August, 2016
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