Page 31 - The TEFRA Partnership Audit Rules Repeal:
P. 31
Budget Act: Partnership Level Interest and Penalties
• If the partnership fails to pay any imputed underpayment "on the date prescribed therefor," the partnership is liable for interest, penalties, additions to tax, and other additional amounts."
• Appears that an imputed underpayment will be due no later than the due date of the partnership's tax return for the adjustment year (determined without regard to extensions).
− Interest: Determined as if the imputed underpayment is an actual underpayment of tax imposed in the adjustment year.
− Penalties, additions to tax, and other additional amounts: Determined (i) by applying section 6651(a)(2) (relating to additions to tax for failing to timely pay) and (ii) treating the imputed underpayment as an actual underpayment of tax for purposes of sections 6662 through 6664 (relating to accuracy and fraud related penalties).
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Coming changes to IRS Audits of partnerships 22
