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Miller & Chevalier Attorneys Assist in ABA Tax Section Comment Letter on New Partnership Audit Rules

The American Bar Association (ABA) Section of Taxation submitted comments on new partnership audit rules enacted as part of the Bipartisan Budget Act of 2015, which made fundamental changes to how the Internal Revenue Service (IRS) will conduct audits of partnerships. Many practitioners provided input on the letter in an effort to help the IRS and the Department of the Treasury draft the guidance required to implement the legislation. The letter recognizes that such guidance will be an "enormous undertaking" for the IRS and Treasury, and provides comments consistent with the overarching motivation behind the legislation, "namely to assist the Service in the assessment and collection of tax due, stemming from adjustments to partnership returns." George Hani, Chair of the ABA Taxation Section, Administrative Practice Committee, was one of two attorneys who took principal responsibility for coordinating the comments; Andy Howlett assisted him. A copy of the letter is available here.