Page 33 - The TEFRA Partnership Audit Rules Repeal:
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Section 6235: Statute of Limitations on Partnership Adjustments
In general, no adjustment for any partnership taxable year may be made after the later of:
• The date which is 3 years after the later of:
− The date that the partnership tax return was filed,
− The return due date for the taxable year, or
− The date that the partnership filed an AAR for the taxable year; or
• In the case of any modification of an imputed underpayment under section 6225(c), the date that is 270 days (as extended) after the date on which everything required to be submitted to the IRS is so submitted; or
• in the case of any NOPA, the date that is 330 days after such notice. Section 6235(a)(3)(as amended by the Protecting American Taxpayers and Homeowners Act of 2015).
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Coming changes to IRS Audits of partnerships 24
