Page 37 - The TEFRA Partnership Audit Rules Repeal:
P. 37
Section 6227
“A partnership may file a request for an administrative adjustment in the amount of one or more items... for any partnership taxable year.”
• Not more than three years after the date on which the return for the year was filed
• Not after notice of administrative proceeding with respect to the taxable year is mailed under section 6231
• Underpayments—rules “similar to” sections 6225 and 6226 will apply
• Overpayments—must be pushed out under rules similar to section 6226
• Bluebook—possibility of coordinated AAR
• Will AAR be mandatory for upper-tier partnership receiving statement described in section 6226(a)?
Copyright © 2016 PricewaterhouseCoopers LLP. All rights reserved. Coming changes to IRS Audits of partnerships 28
