New Rules for Audits of Partnership Returns

6 Tax Dev. J. 50 (2016)

14 Pages Posted: 6 Jan 2020

See all articles by Monica Gianni

Monica Gianni

California State University Northridge

Date Written: March 15, 2016


Effective for audits of partnership returns beginning after 2017, the IRS will use a centralized audit system that requires partnership adjustments to be determined at the partnership level and any tax attributable to the adjustments to be assessed and collected at the partnership level. These new rules allow for a small-partnership opt-out and an elective alternative to “push out” the audit adjustments made and tax paid to the partners. The audit process will be streamlined by limiting the right to notices and participation in the audit to one “partnership representative.” This article presents the new rules and existing guidance that consists of a report by the Joint Committee on Taxation and temporary regulations on an early opt-in to the rules prior to their effective date.

Keywords: partnership audit, BBA audit

Suggested Citation

Gianni, Monica, New Rules for Audits of Partnership Returns (March 15, 2016). 6 Tax Dev. J. 50 (2016), Available at SSRN: or

Monica Gianni (Contact Author)

California State University Northridge ( email )

David Nazarian College of Business and Economics
18111 Nordhoff
Northridge, CA 91330-8372
United States
8186772449 (Phone)

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