Page 56 - The TEFRA Partnership Audit Rules Repeal:

Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative (cont.)
• Multiple Questions:
− To obtain prior approval of the partnership of all filings and pleadings with
the District Court or Court of Federal Claims.
− To obtain prior approval of the partnership of any interrogatories, responses to interrogatories, request for admissions, admissions, or similar matters and to complete and serve these matters.
− To obtain prior approval of the partnership of any depositions.
− To engage partnership experts, subject to prior approval by the
partnership.
− To incur other audit or litigation expenses on behalf of the partnership.
− What are the powers of the partnership representative? Powers might include:
• Conduct the partnership audit in accordance with directives by the partnership.
• Institute and conduct Tax Court action for determination of the tax liability of the partnership and the partners.
• Institute and conduct a suit for refund.
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