sophisticated accounting or finance professional you have a good general grasp of how the IRS audits partnerships and their partners. Your textbook devotes two full chapters to partnerships but does not address IRS audits.

 

Prior to the effective date of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), auditing a partnership effectively meant that the IRS had to audit each and every partner separately. That complete nightmare was partially relieved by TEFRA, which required that most partnerships, including all large partnerships, appoint a so-called Tax Matters Partner (TMP). From that point on and for most purposes, the IRS was required to deal only with the TMP when auditing the part-nership. Correspondingly, the TMP had authority to handle the partnership audit unilaterally, at least for the most part. This is why post-TEFRA Tax Court deci-sions involving partnerships always include the TMP within the style of the case - e.g., Salt Point Timber, LLC, John B. Hood, Tax Matters Partner, v. Commission-er, T.C. Memo. 2017-245.

 

The Bipartisan Budget Act of 2015 (BBA) made major changes once again to the partnership audit rules. Accordingly, TEFRA is now a relic except for continuing audits relating to pre-BBA years. Among other things, the BBA audit regime has  replaced the TMP with the new role of partnership representative . . . and that's all I'll say for now because it's for you to summarize the BBA rules as a supple-ment to textbook chapters 10 and 11.

 

Your task is simple::: Google around and find summaries of the BBA rules (of which there's no shortage). Summarize those rules, but with a focus on -

 

contextualizing the BBA rules as compared to the TEFRA rules, and
highlighting implications for subject-matter inclusion within a partnership agreement (or amendment of an existing (pre-BBA) agreement).
Cite your sources, with footnote links that work, please