Page 250 - 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
 To obtain prior approval of the partnership of any interrogatories, responses to interrogatories, request for admissions, admissions, or similar matters and to complete and serve these matters.
 To obtain prior approval of the partnership of any depositions.
 To engage partnership experts, subject to prior approval by the partnership.
 To incur other audit or litigation expenses on behalf of the partnership.
 What are the powers of the partnership representative? Powers might include:
 Conduct the partnership audit in accordance with directives by the partnership.
 Institute and conduct Tax Court action for determination of the tax liability of the partnership and the partners.
 Institute and conduct a suit for refund.
 Hire counsel and accountants for the audit or other
tax litigation on behalf of the partnership.
 Approve compensation of accountants and counsel.
 Engage experts for the audit or other tax litigation on behalf of the partnership.
 Extend statutes of limitation on behalf of the partnership.
 Enter into settlement agreement with the Internal Revenue Service.
 Pay the audit assessment.
 Choose the forum in which to litigate tax disputes.
 Call for funds to pay the assessment in order to qualify the partnership to sue in District Court or the Court of Federal Claims.
© Terence Floyd Cuff and Jerald David August, 2016
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