Exception for Small Partnerships

ID:
UILC:
CCA_2015012312283801
6231.01-01
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201510046
Release Date: 3/6/2015
From:
Sent: Friday, January 23, 2015 12:28:38 PM
To:
Cc:
Bcc:
Subject: RE: Guaranteed Payments
TEFRA would still likely apply. The TEFRA/non-TEFRA determination is made at the beginning of the audit and does not change based on the audit results. I.R.C. 6231(g) (reliance on partnership return to determine if TEFRA procedures apply); Harrell v.
Commissioner, 91 T.C. 242 (1988); Nehrlich v. Commissioner, 2009 WL 1284067 (9th
Cir. 2009); Doe v. Commissioner, 116 F.3d 1489 (10th Cir. 1997).