Page 42 - The TEFRA Partnership Audit Rules Repeal:
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Requirements to file amended returns or provide information
Adjustment of distributive share
• In the case of any adjustment that reallocates distributive share, imputed underpayment can be reduced only if all affected partners file amended returns —can partnership or PR compel?
Will regulations require additional partner-level information?
• Reduction of imputed underpayment under 6225 may require partners to provide additional information to the partnership—does agreement have a general provision requiring cooperation with PR?
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