Posts from April 2021.
On April 14, 2021, the IRS released a memorandum clarifying that partners and partnership representatives of TEFRA or BBA partnerships are entitled to request and receive IRS administrative file records containing partnership returns and return information, including any supporting schedules, attachments, or lists which include identifying information of persons other than the requesting party. This memorandum serves as guidance to taxpayers pending an update to the Internal Revenue Manual.
Internal Revenue Code section 6103(e) details which parties may access returns ...
A New Era of Partnership Representation Before the IRS
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Recent Blog Posts
- Surge in BBA Partnership Audits Expected in 2022
- IRS Releases Memo Concerning Access to Administrative File in TEFRA and BBA Examinations
- IRS Provides Penalty Relief for New Capital Reporting Requirements
- IRS Releases Proposed Regulations on Centralized Partnership Audit Regime
- Centralized Partnership Audit Regime Website Launched by IRS
- Partnership Filing Relief
- IRS Issues LB&I Memorandum
- IRS Release Clarifications for Form 8082
- IRS Release Draft Instructions to Form 8978
- IRS Releases Interim Guidance Centralized Partnership Audit Regime
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