Page 52 - The TEFRA Partnership Audit Rules Repeal:
P. 52
Partnership Agreement Provisions (cont.)
Provisions With Respect to Push-Out Election under Section 6226(b)
• Multiple Questions:
− Should the partnership make the push-out election?
− How is the push-out election approved by the partnership? − How is the election revoked by the partnership?
• The partners should commit to provide the information necessary to enable the partnership to make the push out election.
• Retained right of partnership representative to seek judicial review
• Consistent Reporting Requirement. The partnership agreement might mirror
the consistency requirement of Section 6222. But see Section 6222(c).
Copyright © 2016 Kostelanetz & Fink, LLP Coming changes to IRS Audits of partnerships 43
