Practitioners Disappointed by Partnership Audit Rules Provision

Tax attorney Lee Meyercord was quoted in a Bloomberg Tax article about final rules released by the Internal Revenue Service (IRS) concerning the centralized audit process in which the IRS typically assesses any tax underpayment at the partnership level.

"In my view, this regulation is inconsistent with Congress' clear directive in the Bipartisan Budget Act of 2015 (BBA) that the statue of limitations be determined exclusively at the partnership level," she said.

Ms. Meyercord also took issue with the IRS' comment in the preamble that the exception isn't an extension of the statute of limitations. 

"The rule absolutely has the effect of extending the statue of limitations for adjustments on the partnership items because, by its terms, it only applies if the partnership level statue of limitations has expired," she explained. 

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