Page 18 - The TEFRA Partnership Audit Rules Repeal:
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Major Partnership Changes in the BBA (cont.)
Partnership Representative— Binds the partnership and the partners
Imputed Underpayment— Net adjustments x highest tax rate
Section 6225 Payment—The default rule where the partnership pays the imputed underpayment
Section 6226 Payment— Partnership election to push out the imputed underpayment to reviewed year partners
Key Terms and Shorthand References
Reviewed Year—
The partnership tax year under examination
Adjustment Year —The year in which the adjustment is made or becomes final
Election Out for Small Partnerships— Annual option for qualifying partnerships
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Coming changes to IRS Audits of partnerships 9
Election In—Early application of the BBA to electing partnerships
