Page 251 - 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
 Incur reasonable audit expenses on behalf of the partnership.
 Incur travel expenses related to the audit.
 Make reports to the partnership concerning
partnership audits and tax litigation.
 Seek information from partners in connection with the audit.
 The partnership agreement should impose limitations on the authority of the representative. Partnership management may wish these controls:
 Approve in advance all written submissions by the partnership representative to the Internal Revenue Service or to a court.
 Approve in advance all extensions of statutes of limitations.
 Approve choice of forum for judicial actions.
 Approve in advance any court filings.
 Approve engagement and discharge of accountants to handle the audit.
 Approve engagement and discharge of attorneys.
 Approve payment of legal and accounting invoices.
 Approve communications to partners.
 Approve settlements with the Internal Revenue Service.
 Selection and removal of the partnership representative.
 Selecting the partnership representative.
 Removing the partnership representative.
 Replacing the partnership representative.
 What is the term for the partnership representative?
 How is the partnership representative removed?
 For cause?
 Without cause?
© Terence Floyd Cuff and Jerald David August, 2016
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