Megan L. Brackney participated in the panel "Anticipating IRS Audits, Controversies and Litigation Under the Partnership Audit Rules," at the 78th Institute on Federal Taxation on October 23, 2019 in New York, NY.
Now that entities taxed as partnerships and their tax advisors have had three years to understand and put into place procedures as well as revisions to outstanding partnership and LLC operating agreements to adapt to the new partnership audit rule regime, the focus now turns to how tax audits, appeals, settlements, litigation and appeals of adverse judicial determinations will work in ―real time‖. The Co-Chairs addressed problems associated with elections-out, understatement modifications, push-outs and pull-ins as well as how partners can protect themselves from the partnership representative’s unilateral authority to settle out all partnership issues. Continuing applicability of the TEFRA audit rules for tax years beginning on or before 2017 were discussed.
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