Page 58 - The TEFRA Partnership Audit Rules Repeal:

Partnership Agreement Provisions (cont.)
Provisions on the Partnership Representative (cont.)
• What are the powers of the partnership representative? Powers might include: (cont.)
− Make reports to the partnership concerning partnership audits and tax litigation.
− Seek information from partners in connection with the audit.
• The partnership agreement should impose limitations on the authority of the
representative. Partnership management may wish these controls:
− Approve in advance all written submissions by the partnership representative to the Internal Revenue Service or to a court.
− Approve in advance all extensions of statutes of limitations.
− Approve choice of forum for judicial actions.
− Approve in advance any court filings.
− Approve engagement and discharge of accountants to handle the audit.
− Approve engagement and discharge of attorneys.
− Approve payment of legal and accounting invoices.
− Approve communications to partners.
− Approve settlements with the Internal Revenue Service.
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