In a recent Law360 article, Kat Gregor commented on the IRS's final guidance on partnership audit rules. This new guidance finalizes a subset of the IRS rules implementing the audit regime passed in the 2015 Bipartisan Budget Act. A key aspect of the final rules is the definition of "partnership related items," which looks to historic rules to define the scope of the new regime. While some may argue that the ambiguity of the TEFRA rules has crept into the new partnership audit regulations, Kat noted that "TEFRA had a 'robust body of case law' behind it that could help resolve future disputes around what a partnership- related item is."

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