Page 54 - The TEFRA Partnership Audit Rules Repeal:
P. 54
Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative (cont.)
• Multiple Questions:
− How does the partnership select a replacement partnership
representative?
− What are the duties of the partnership representative? These duties might include:
• To undertake the partnership audit, using the partnership accountants and counsel.
• To undertake litigation on behalf of the partnership in the United States Tax Court, District Court, or Court of Federal Claims.
• To copy the partnership on all notices and other correspondence from the Internal Revenue Service?
• To consult with partnership management concerning audit strategy?
• To represent the partnership in audits in accordance with agreed audit
strategy?
• To seek approval of all written audit submissions to the Internal Revenue Service in advance.
• To seek advance partnership approval of all waivers of statutes of limitations.
• To waive statutes of limitation in accordance with this approval.
• To seek prior written approval of the settlement with the Internal
Revenue Service.
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