Navigating the TEFRA Swamp: Managing the Complexities of a Partnership Audit

Posted by Mary McNulty  Mary McNulty spoke as part of a panel advising on “Navigating the TEFRA Swamp:  Managing the Complexities of a Partnership Audit” at the American Bar Association Section of Taxation 2015 Midyear Meeting.  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. The panel discussed some of the basics of a TEFRA audit and focused on particular complexities that can often baffle even a veteran tax controversy attorney. In addition, the panel discussed recent reports regarding the current state of TEFRA audits as well as some proposals for reform of the TEFRA system.  The other panel members were Sheri Dillon, Vinson & Elkins, Washington, DC, The Honorable Ronald L. Buch, Judge, US Tax Court, Washington, DC; Janet R. Balboni, Senior Attorney, Office of Chief Counsel, IRS, Large Business and International Division, Houston, TX; and Thomas L. Fenner, Attorney, Office of Chief Counsel, IRS, Small Business and Self-Employed Division, Houston, TX.