The Bipartisan Budget Act (BBA) was signed into law by President Barack Obama in 2015 and fundamentally changed the way partnerships are audited. Under the BBA, the IRS generally.
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On September 1, 2020, as a first step in its stated intention to
increase Partnership audits in 2021, the Internal Revenue Service
added a new section,
BACKGROUND
Before January 1, 2018, when the IRS audited a partnership
(including any entity taxed as a partnership, like the typical
limited liability company), and tax, interest or penalties were
owed, the IRS could only collect from the individual partners. For
small partnerships or LLC s (ten or fewer partners or members),
the IRS had to audit each partner or member, too. For larger
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