Page 57 - The TEFRA Partnership Audit Rules Repeal:
P. 57
Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative (cont.)
• What are the powers of the partnership representative? Powers might include: (cont.)
− Hire counsel and accountants for the audit or other tax litigation on behalf of the partnership.
− Approve compensation of accountants and counsel.
− Engage experts for the audit or other tax litigation on behalf of the
partnership.
− Extend statutes of limitation on behalf of the partnership.
− Enter into settlement agreement with the Internal Revenue Service.
− Pay the audit assessment, i.e., the imputed underpayment, including additions to tax.
− Choose the forum in which to litigate tax disputes.
− Call for funds to pay the assessment in order to qualify the partnership to
sue in District Court or the Court of Federal Claims.
− Incur reasonable audit expenses on behalf of the partnership.
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