Attys Tell IRS To Narrow Partnership Audit Rule Exceptions

Proposed regulations exempting special enforcement matters from the centralized partnership audit regime should be applied narrowly and the government should strike a provision allowing partnerships adjustments in a partner-level audit, a tax attorney said in an IRS public hearing Thursday. Lee S. Meyercord, a tax partner at Thompson & Knight LLP, said the Internal Revenue Service's decision to use a special enforcement exception to make partnership adjustments in a partner-level audit may make sense from an efficiency standpoint. However, this conflicts with Congress' general directive behind enacting the Bipartisan Budget Act of 2015, which was that partnership adjustments should be made in a partnership-level audit, she said, and not a partner-level audit.

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