With everyone happy that TEFRA is going away, the IRS has decided to try to implement these new rules earlier. Now, starting with partnerships with a tax year of Nov. 2, 2015 or later, if the IRS sends an audit notice for the partnership, the partnership has 30 days to file an election to fall under the new partnership audit guidelines.
The details on the election can be found in Temp Reg 301.9100-22T. This is a great tool for the future to get out of TEFRA procedures.
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