Audits of Large Partnerships: Where Do We Go from Here?: Part 5 of 9 Tax Audits and Litigation Tax Series

Date & Time: Thursday, February 26, 2015 from 12:00 pm to 1:30 pm

CLE Credit: No

Event Description

In 2008, partnerships reported over 33% of the total net business income in the U.S. while C corporations reported around 27%. From 2001 to 2011, the number of C corporations declined by 22% while the number of large partnerships more than tripled during roughly the same timeframe. Large partnerships, many of which are complex fund structures in the finance and insurance industries, collectively hold trillions of dollars of assets. The long-standing shortcomings of the unified partnership audit procedures of the Tax Equity and Fiscal Responsibility Act (TEFRA) have reached a breaking point, with Congress and the IRS taking notice.

This expert panel will review the history of and current law under TEFRA, and discuss its practical strengths and weaknesses and how it might be improved. The panel will also discuss the extent of partnership noncompliance. The panelists will provide their different perspectives on recent proposals to strengthen partnership audits, including prominent proposals by panelist Noel Brock.

This luncheon program is sponsored by the Tax Audits and Litigation Committee of the D.C. Bar Taxation Section. Doors will open at 11:30 a.m.

D.C. Bar Conference Center
1101 K Street, NW, Conference Center
(Metro Center Station)
Washington DC 20005
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Contact Information
Sections Office
Phone: 202-626-3463
Fax: 202-824-1877


  • Noel P. Brock, Assistant Professor, West Virginia University
  • William A. Heard III, Senior Counsel, IRS Office of the Associate Chief Counsel (Procedure & Administration)
  • Charles E. Hodges II, Partner, Kilpatrick Townsend & Stockton, LLP
  • Rosemary J. Sereti, Assistant Deputy Commissioner for Services and Enforcement, Internal Revenue Service


Government Brown Bag (Please Bring Government ID)


Government or Non-Profit Employee


Law Student (Please bring student ID)


Non-Section Member


Taxation Section


Printable registration form