Recent Developments In The IRS Partnership Audit Regime
By David Blair and Teresa Abney ( January 18, 2019, 5:44 PM EST) -- In the last two weeks of December, there was a flurry of activity surrounding the implementation of the centralized partnership audit regime. Release of the final partnership regulations on Dec. 21, the government shutdown and, hopefully, holiday celebrations may have overshadowed two important announcements. First, on Dec. 19, 2018, the U.S. Tax Court issued new proposed rules implementing the new partnership regime. Second, on Dec. 20, 2018, the Internal Revenue Service announced its intention to issue new proposed regulations on two new topics related to implementation of the new centralized partnership audit regime. If you missed either announcement, below is a discussion of the new court rules and the to-be-proposed regulations....
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