White Paper

5 Pages
  • 5 Pages

Partnership Tax Audit and Collection Rules: Administrative Adjustment Requests (Section 6227)


Gain an understanding of when partnerships may file administrative adjustment requests.

The Administrative Adjustment Requests provisions generally describe the procedures for amending partnership returns and filing related refund claims. A partnership may file a request for an administrative adjustment with respect to any partnership-related item for any partnership taxable year. Reg. A partner may not file an AAR except if the partner is doing so on behalf of the partnership in the partner’s capacity as the partnership representative. In addition, a partnership may not file an AAR solely for the purpose of changing the designation of the partnership representative or changing the appointment of a designated individual. This white paper reviews determinations and period of limitations and discusses partner modifications.



Charles D. Pulman

Charles D. Pulman

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

  • Tax partner with the Dallas law firm of Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
  • Practice focuses primarily on federal tax planning and compliance with extensive experience representing taxpayers under IRS audit and the resulting administrative and judicial proceedings
  • Extensive experience representing entities taxed as partnerships and their partners
  • Represents clients on tax matters throughout the United States
  • Board certified in tax law by the Texas Board of Legal Specialization; he is also a Certified Public Accountant
  • Writes and speaks extensively on tax related topics and has written and spoken on several occasions with regard to the new IRS audit regime affecting partnerships
  • Recognized by his peers as a Texas Super Lawyer and recognized as one of the Best Lawyers in Dallas by D magazine
  • LL.M. degree in taxation, New York University
  • Can be contacted at 214-749-2447 or [email protected]
Mary E. Wood

Mary E. Wood

Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

  • Partner with the law firm Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.
  • Practice concentrates on resolving federal and state tax controversies, and white collar crime such as securities, tax and bank fraud
  • Represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Courts, Federal District Courts and United States Court of Federal Claims; she also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies
  • Represents individuals and entities in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, noncompete violations, business torts, and other commercial disputes
  • Texas Rising Stars, as published in Texas Monthly and in Texas Super Lawyers - Rising Stars Edition and on the web at superlawyers.com, Tax-2013-2019; Best Lawyers Under 40, D Magazine, 2017
  • J.D. degree, with honors, University of Texas School of Law; B.B.A. degree in accounting, Texas A&M University
  • Can be contacted at 214-744-3700 or [email protected]

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