By Megan L. Brackney
Journal of Passthrough Entities
September - October 2012 Edition
Although representing a small partnership in a tax controversy may seem less complicated than navigating TEFRA,1 there are many tactical, procedural and ethical issues that must be analyzed to effectively represent the small partnership. Because TEFRA partnerships and non-TEFRA partnerships are each subject to different procedures for audit, assessment and judicial review, the initial question the practitioner must ask is whether TEFRA applies.