-5- for San Francisco. The parties then submitted it for decision on stipulated facts. Discussion As a general rule, partnerships don’t pay taxes, and items of a partnership’s income, deductions, and credits are supposed to be reflected on its partners’ individual tax returns. See sec. 701. Before TEFRA, the IRS adjusted these partnership items after separately auditing each partner. This easily led to inconsistent adjustments, and TEFRA’s requirement that the Commissioner conduct audits at the partnership level was supposed to ensure the uniform adjustment of partnership items. Maxwell v. Commissioner, 87 T.C. 783, 787 (1986); H. Conf. Rept. 97-960, at 599-600 (1982), 1982-2 C.V. 600, 662-63. Though the procedures are complicated, the desired result is easy to understand--a final determination concerning a partnership item that binds all the partners and treats them equally. See sec. 6221; Maxwell, 87 T.C. at 787-88. TEFRA audits, with their sometimes arcane distinctions between “partnership,” “affected,” and “nonpartnership” items, can be burdensome, so Congress chose to keep the old audit rules under which each partner resolves his tax liability with the IRS separately, for “small partnerships.” Tax Compliance Act of 1982 and Related Legislation: Hearings on H.R. 6300 Before the House Committee on Ways and Means, 97th Cong., 2d Sess. 259-61 (1982).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007