Partnerships: IRS Audit Techniques Guide

This Guide is designed to assist examiners in classifying and examining partnership returns. The focus is on issues that fall within sections 701 through 761 of the Code (Subchapter K). Subchapter K deals primarily with the formation, operation, and termination of partnerships. Many issues arise during the initial or final year of the partnership. If your return relates to an operating business (as opposed to rentals), you should also look for an MSSP Guide for that type of business. The Tax Equity and Fiscal Responsibility Act of 1982 created the "TEFRA Entity." Returns qualifying as TEFRA Partnerships and their partners are subject to these "unified procedures" which are contained in IRC sections 6221-6234. The procedures are briefly explained in Chapter 13.