Page 24 - The TEFRA Partnership Audit Rules Repeal:

TEFRA v. BBA—Comparison (cont.)
Rules Relating to Modification of Imputed Underpayment
TEFRA
• Not applicable under TEFRA
BBA
• The imputed underpayment can be modified:
̶ If the reviewed-year partners file amended returns and pay their portion of the imputed underpayment
̶ If the partnership demonstrates an allocable share of the imputed underpayment to a tax- exempt entity
̶ If the partnership demonstrates that a lower tax rate applies to some portion of the imputed underpayment
• Information demonstrating entitlement to modification must be submitted within 270 days after the notice of proposed adjustment
• IRS must consent to such modification
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