Page 249 - The TEFRA Partnership Audit Rules Repeal:
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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
To seek approval of all written audit submissions to the Internal Revenue Service in advance.
To seek advance partnership approval of all waivers of statutes of limitations.
To waive statutes of limitation in accordance with this approval.
To seek prior written approval of the settlement with the Internal Revenue Service.
To enter into settlements with the Internal Revenue Service?
To seek prior written approval of any closing agreements and to enter into closing agreements with the Internal Revenue Service on behalf of the partnership.
To obtain the prior approval of the partnership for any petition in the Tax Court and to file this approved petition with the Tax Court.
To seek resolution of tax disputes in the Tax Court.
To seek prior approval of all filings and pleadings with
the Tax Court.
To make any tax payments necessary to establish the jurisdiction of the District Court or Court of Federal Claims.
To obtain the prior approval of the partnership for any petition in the District Court or Court of Federal Claims and to file this approved petition with the District Court or Court of Federal Claims.
To seek resolution of tax disputes in the District Court or Court of Federal Claims.
To obtain prior approval of the partnership of all filings and pleadings with the District Court or Court of Federal Claims.
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