By Megan L. Brackney
Journal of Passthrough Entities
January - February 2015 Edition
The rapid growth of the use of partnerships, as well as the increase of large partnerships with complex structures, puts more pressure on the IRS to properly and efficiently execute the procedures for auditing partnership returns under TEFRA. 1 Th is column discusses the difficulty that the IRS has with the first step of any TEFRA audit, identifying the tax matters partner (the “TMP”). After a brief discussion of the qualifications for TMPs and the methods for identifying the TMP, this column discusses how the common-law doctrine of equitable estoppel, as well as tax practitioners’ duties under Circular 230, relate to this issue.