The number of large partnerships has more than tripled to 10,099
from tax year 2002 to 2011. Almost two-thirds of large partnerships
had more than 1,000 direct and indirect partners, had six or more
tiers and/or self-reported being in the finance and insurance
sector, with many being investment funds. The Internal Revenue
Service (IRS) audits few large partnerships. Most audits resulted
in no change to the partnership's return and the aggregate change
was small. Although internal control standards call for information
about effective resource use, IRS has not defined what constitutes
a large partnership and does not have codes to track these audits.
According to IRS auditors, the audit results may be due to
challenges such as finding the sources of income within multiple
tiers while meeting the administrative tasks required by the Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA) within
specified time frames. This book determines what IRS knows about
the number and characteristics of large partnerships; assesses
IRS's ability to audit them; and also assess IRS's efforts to
address the audit challenges.
General
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