Tread Carefully: Extension Agreements in Tiered Partnerships.


Tread Carefully: Extension Agreements in Tiered Partnerships.

In the course of an audit, taxpayers may be requested to waive the assessment limitations to permit the audit to be completed. The waiver can (and frankly should ) be limited to specific issues. A recent Ninth Circuit case demonstrates that caution is required in examining the scope of an extension agreement in the context of tiered partnerships.

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