Page 29 - The TEFRA Partnership Audit Rules Repeal:

Section 6232: Partnership Level Assessment, Collection and Payment
• Any imputed underpayment arising from audit adjustments will be assessed and collected in the same manner as if it were a tax imposed on the partnership for the adjustment year.
• Limitation on assessment:
− No assessment of a deficiency may be made before (i) the close of the 90th day after the date on which the FPA was mailed and (ii) if the partnership challenges the FPA in court, the date the decision of the court becomes final.
− Limitation period subject to waiver by the partnership.
• Rules similar to section 6213(b) will apply to mathematical and clerical errors
rules.
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Coming changes to IRS Audits of partnerships 20