“TEFRA Unit to Be Retooled for Partnership Audit Modification”
The IRS is planning to revamp its partnership audit unit in Ogden, Utah, to handle modification requests under the new partnership audit regime. Under the new regime (REG-136118-15), a partnership representative may, within 270 days of receiving a notice of proposed partnership adjustment, request a modification on an imputed underpayment, which must be approved by the IRS.
…Asked by Mary McNulty of Thompson & Knight LLP what a taxpayer’s recourse would be if the Ogden unit “doesn’t get it right,” Paz said the IRS is still determining how appeals will work, but that appeals rights wouldn’t be weakened under the new regime. The IRS would make its decision clear to the public, potentially in the Internal Revenue Manual, she added.