Tax practitioners expressed disappointment that the IRS did not agree with comments concerning statute of limitations in its final regulations about partnership audits.
The IRS last week released final rules (TD 9969, RIN: 1545-BP01) relating to the centralized audit process under the Bipartisan Budget Act of 2015—a process under which the IRS typically assesses any tax underpayment at the partnership level.
A major portion of the regulations outlined circumstances when the centralized audit procedures don’t apply. One of those exceptions allows the IRS in certain circumstances to make adjustments to partnership-related items when the statute of limitations for the ...
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