Page 51 - The TEFRA Partnership Audit Rules Repeal:
P. 51
Partnership Agreement Provisions (cont.)
Provisions With Respect to Electing Out of the Partnership Audit Rules
• Cooperation of partnership to allow access to tax return information of partnership including transactional documentation
• Cooperation of partners to provide any information necessary to enable an election out
• Multiple Questions:
− Does the partnership have adequate provisions concerning financial
contribution to joint defense?
− Is a partner entitled to inspect books and records in defense of an audit? − Information sharing by partners under audit
− Required use of partnership advisers?
− What confidentiality provisions will apply?
Copyright © 2016 Kostelanetz & Fink, LLP Coming changes to IRS Audits of partnerships 42

