Outside Publication

The TEFRA Swamp: Managing the Complexities of a Partnership Audit

Bloomberg BNA Tax Management Real Estate Journal

May 2015

The recent attention given to partnership audits likely will lead to more such audits, and in particular, to audits of large partnerships. The TEFRA procedures for partnership audits add layers of procedural complexity to already difficult partnership issues.

This publication discusses some of the basics of a TEFRA audit and focuses on particular complexities that can often baffle even a veteran tax controversy attorney. This article also discusses recent reports regarding the current state of TEFRA audits as well as some proposals for reform of the TEFRA system. 

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