Page 41 - The TEFRA Partnership Audit Rules Repeal:

Future audits and examinations
Will the buyer have notice and participation rights?
Are there terms of the agreement that would require/prevent the push- out election?
Who is the partnership representative (“PR”) and what limits are imposed on PR’s ability to settle, elect push-out, etc.?
If partner is a general partner, could it have joint and several liability for taxes imposed under section 6225?
Can the partnership elect out of the BBA provisions?
• Any limits on transfer to persons whose ownership could affect election out, e.g., partnerships or even disregarded entities
• Example: partnership has 100 individual partners, one partner transfers interests to LLC, disregarded from partner for most US federal income tax purposes
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