Page 30 - The TEFRA Partnership Audit Rules Repeal:
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Section 6233: Partnership Level Interest and Penalties
• If there is a partnership adjustment for a reviewed year, interest is required to be computed and the partnership is liable for any penalty, addition to tax or additional amounts.
− Interest: Interest is determined during the period (i) beginning on the day after the return due date for the reviewed year and (ii) ending on the return due date for the adjustment year (or, if earlier, the payment of the imputed underpayment). Proper adjustments to the interest so determined will be made on account of partnership adjustments required for taxable years after the reviewed year and before the adjustment year.
− Penalties, Additions to Tax, and Other Amounts: Determined as if partnership had been taxable as an individual for the reviewed year and the imputed underpayment was an actual underpayment for the reviewed year.
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Coming changes to IRS Audits of partnerships 21
