Page 34 - The TEFRA Partnership Audit Rules Repeal:

Section 6235: Statute of Limitations on Partnership Adjustments (cont.)
• Period may be extended by agreement (provided statute has not already expired).
• 6-year statute for substantial omission of income (as determined under section 6501(e)(1)(A)).
• No time limit in the following cases:
− Filing of false or fraudulent partnership return with intent to evade tax.
Section,
− No return filed, or
− IRS prepares return on partnership's behalf under section 6020.
• If an FPA is mailed for a taxable year, the statute for making adjustments is suspended:
− For the period during which the partnership can file a petition for readjustment, and
− For 1 year thereafter.
©2016 Sutherland Asbill & Brennan LLP
Coming changes to IRS Audits of partnerships 25