Taxpayers often use entities characterized as partnerships for federal income tax purposes to conduct their business activities. In addition to offering limited liability (e.g., limited liability ...

In tax controversy and litigation matters, sometimes procedure trumps the merits. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS ...

Because a limited liability company (LLC) made a valid early election into the audit and examination regime of the Bipartisan Budget Act (BBA), P.L. 114-74, the IRS’s final partnership administrative ...

IRS examinations of partnerships under the procedures of the Bipartisan Budget Act (BBA) of 2015, P.L. 114-74, more often ended with no additional tax liability proposed than for all partnership ...