In Round 1, the Administrative Law Committee covered what will happen during the audit. In Round 2, we discuss the Final Partnership Adjustment (“FPA”) and what options partnerships have following the end of the audit, including challenges to the adjustments in the FPA. We also discuss the assessment and collection of imputed underpayments and penalties under the new regime, including the operation of the push-out election.
Moderators: Robert J. Kovacev, Steptoe & Johnson LLP, Washington, DC; Rebecca M. Stork, Eversheds Sutherland LLP, Atlanta, GA
Panelists: Jean A. Pawlow, Latham & Watkins LLP, Washington, DC; Megan L. Brackney, Kostelanetz & Fink LLP, New York, NY; Gregory A. Armstrong, Senior Technical Reviewer, IRS Chief Counsel, Washington, DC (Invited); Deborah S. Meland, Chief, Eastern Civil Trial Section, Department of Justice, Tax Division, Washington, DC (Invited)
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Atlanta, GA 30303
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