Treasury Decision 8965 - Unified Partnership Audit Procedures

SUMMARY: This document contains final Books or records relating to this collec-Section 6221.—Tax Treatmentregulations relating to the unified partnership tion of information must be retained asDetermined at Partnership Levelaudit procedures added to the Internal long as their contents may become mater-26 CFR 301.6221–1: Tax treatment determined at Revenue Code by the Tax Equity and Fiscal ial in the administration of any internalpartnership level. Responsibility Act of 1982 (TEFRA), and revenue law. Generally, tax returns andamended by the Taxpayer Relief Act of 1997 tax return information are confidential, asT.D. 8965(1997 Act) and the Internal Revenue Service required by 26 U.S.C. 6103.Restructuring and Reform Act of 1998 (1998BackgroundDEPARTMENT OF THE TREASURY Act). The unified partnership audit proce-dures provide administrative rules for theInternal Revenue Service These regulations finalize the regulationsauditing of a partnership and its partners. 26 CFR Parts 301 and 602 proposed December 13, 1984 (L.R. 242–84,1984–2 C.B. 917 [49 FR 48573]), April 18,EFFECTIVE DATES: These regulationsUnified Partnership Audit1986 (L.R. 205–82, 1986–1 C.B. 782 [51are effective October 4, 2001.Procedures FR 13231]), and January 26, 1999FOR FURTHER INFORMATION CON- (REG–106564–98, 1999–1 C.B. 714 [64 FRAGENCY: Internal Revenue ServiceTACT: William Heard at (202) 622-7950 3886]) and issued as temporary regulations(IRS),Treasury.(not a toll-free number). on December ...