Modifications and Additions to the Unified Partnership Audit Procedures

[4830-01-u]DEPARTMENT OF THE TREASURYInternal Revenue Service26 CFR Part 301[TD 8808]RIN 1545-AW23Modifications and Additions to the Unified Partnership AuditProceduresAGENCY: Internal Revenue Service, Treasury.ACTION: Final and temporary regulations.SUMMARY: This document contains final and temporary regulationsrelating to the unified partnership audit procedures added to theInternal Revenue Code by the Tax Equity and Fiscal ResponsibilityAct of 1982 (TEFRA). The unified partnership audit proceduresgenerally provide administrative rules for the auditing ofpartnership items at the partnership level. These regulationsmodify the existing unified partnership audit procedures tocomply with the Taxpayer Relief Act of 1997 (1997 Act) and theInternal Revenue Service Restructuring and Reform Act of 1998(1998 Act), and add new regulations to administer the new unifiedpartnership audit provisions added by the 1997 Act. In general,the text of these temporary regulations also serves as the textof the proposed regulations set forth in the notice of proposed-2-rulemaking on this subject in the Proposed Rules section of thisissue of the Federal Register.DATES: Effective Date: These regulations are effective January26, 1999. FOR FURTHER INFORMATION CONTACT: Robert G. Honigman, (202) 622-3050 (not a toll-free number).SUPPLEMENTARY INFORMATION: BackgroundThis document contains temporary amendments to the Procedureand Administration Regulations (26 ...