Page 68 - The TEFRA Partnership Audit Rules Repeal:

Is ignorance bliss? Perhaps.
“Tax Audits For Taxable Years Ending After December 31, 2017. The Bi-Partisan Budget Act of 2015 contains, among other provisions, revisions to the federal partnership audit rules. The new federal partnership audit rules will be effective for tax years commencing after December 31, 2017. Before the new federal partnership audit rules become effective, the Managers, in their sole discretion, will amend this Agreement as they view, in their sole discretion, necessary or desirable to address the new federal partnership audit rules. The Managers will select the “partnership representative” (as defined in the new federal partnership audit rules). The Managers will have the right to authorize any elections or consents required or permitted to be made by a partnership representative under the new federal partnership audit rules.”
Copyright © 2016 Kostelanetz & Fink, LLP Coming changes to IRS Audits of partnerships 59