All of the following statements regarding the centralized partnership audit regime are true

except:

a) Partnerships with 100 or fewer eligible partners may elect out of the general rule.

b) The election out of the centralized partnership audit regime is made annually on a timely

filed return, including extensions.

c) Prior to the Bipartisan Budget Act's centralized partnership audit regime, partnerships with

100 or more partners in the preceding tax year could be eligible for an election to be treated

as an electing large partnership.

d) Only half of the partners must be eligible partners for the entire time during the year that

they are partners in order to elect out of the centralized partnership audit regime.