Posts from December 2018.

On December 19, 2018, the United States Tax Court announced that it had adopted interim and proposed amendments to its Rules of Practice and Procedure pertaining to “Partnership Actions?? under the BBA.  The new rules are at Rules 255.1 through 255.7 and have been published in proposed form to allow for notice and public comment.

The rules generally track the structure of the rules pertaining to partnership actions under TEFRA, while substituting in key definitional and procedural changes as set forth by the BBA.  Among other rules, Rule 255.6 grants the court the power to take such ...

Final Partnership Audit Regulations (December 21, 2018) READ MORE

On November 28, 2018, the Internal Revenue Service (the “IRS??) published a draft version of the instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form (click here).  When read in conjunction with the previously published draft of Form 8979, taxpayers now have a clearer idea as to the process for how to change a previously selected partnership representative or designated individual. 

Per the instructions, only the partnership or the partnership representative may file a Form 8979.  Additionally, both the form and the ...

A New Era of Partnership Representation Before the IRS

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