Page 55 - The TEFRA Partnership Audit Rules Repeal:
P. 55
Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative (cont.)
• Multiple Questions:
− What are the duties of the partnership representative? These duties might
include: (cont.)
• To enter into settlements with the Internal Revenue Service?
• To seek prior written approval of any closing agreements and to enter into closing agreements with the Internal Revenue Service on behalf of the partnership.
• To obtain the prior approval of the partnership for any petition in the Tax Court and to file this approved petition with the Tax Court.
• To seek resolution of tax disputes in the Tax Court.
• To seek prior approval of all filings and pleadings with the Tax Court.
• To make any tax payments necessary to establish the jurisdiction of the District Court or Court of Federal Claims.
• To obtain the prior approval of the partnership for any petition in the District Court or Court of Federal Claims and to file this approved petition with the District Court or Court of Federal Claims.
• To seek resolution of tax disputes in the District Court or Court of Federal Claims.
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