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Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Freeman Law

Tax Court in Brief | Deitch v. Comm’r; and Barry v. Comm’r | Deductible Interest Under IRC 163

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Tax Litigation:  The Week of August 22nd, 2022, through August 26th, 2022 Warner Enterprises, Inc. v. Comm’r, T.C. Memo. 2022-85 | August 22, 2022 | Buch, J. | Dkt. No. 17163-19L. ...more

Freeman Law

Tax Court in Brief | Warner Enters., Inc. v. Comm’r | TEFRA and Partner’s Belated Objection to Penalty Determination

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Tax Litigation:  The Week of August 22nd, 2022, through August 26th, 2022 Alexander C. Deitch v. Comm’r, No. 21282-17; and Jonathan D. Barry and Susan S. Barry v. Comm’r, No. 21283-17, T.C. Memo 2022-86 | August 25, 2022 |...more

Whitman Legal Solutions, LLC

If One Musician Plays A Wrong Note, the Entire Orchestra Now May Pay the Price -- Be Aware of New Partnership Tax Audit Rules

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In 1985, the “participatory journalist” George Plimpton worked as a temporary percussionist, playing sleigh bells, triangle, bass drum, and most notably, gong, with the New York Philharmonic. During a performance, he once...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

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On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Partridge Snow & Hahn LLP

Holding the Bag: Update Your Operating Agreement or Face the Tax Consequences

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New Law – Direct Assessment of LLC Tax Liability - The Tax Equity and Fiscal Responsibility Act (“TEFRA”) has governed the procedures for auditing partnerships since 1982. Under TEFRA, if the IRS audited an LLC taxed as a...more

Butler Snow LLP

Partners Beware: New Audit Rules May Have a Big Impact on Your Bottom Line. Here’s What You Need to Know and How to Protect...

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The arcane rules surrounding partnership audits rarely, if ever, come up, and most people don’t even know that they exist. What once was a set of rules confined to the dark recesses of the Internal Revenue Code are now...more

Lowndes

Five Things You Need to Know Now About the New Partnership Audit Rules

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Currently, most federal income tax audits of partnerships are governed by TEFRA, the Tax Equity and Fiscal Responsibility Act of 1982. In the simplest terms, TEFRA provides for a partnership audit to be conducted at the...more

Morgan Lewis

New Legislation Makes Sweeping Changes Impacting All Partnerships

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All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

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