Page 26 - The TEFRA Partnership Audit Rules Repeal:

TEFRA v. BBA—Comparison (cont.)
How are Penalties Treated?
TEFRA
• Penalties determined at both the partnership and partner level
• Defenses may be asserted at both the partnership and partner level
BBA
• Penalties and defenses are determined at the partnership level
• The partnership is liable for penalties, additions to tax and additional amounts
̶ Interest and penalties potentially associated with the partnership’s failure to pay an imputed underpayment in a timely manner
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