White Paper

8 Pages
  • 8 Pages

Partnership Tax Audit and Collection Rules: Assessment and Collection (Section 6232)


Review methods for assessing and collecting.

Partnership audit rules changed how entities are taxed as partnerships. The imputed underpayment amount is assessed and collected in the same manner as if it were a tax imposed for the adjustment year by subtitle A of the tax code and the underpayment must be paid when the request is filed. Upon receipt and demand, an imputed underpayment amount must be paid by the partnership at the time and place stated in the IRS notice. If an adjustment is made through the filing of an administrative adjustments request and taken into account by the partnership, payment of the imputed underpayment amount is due on the date the administrative adjustments request is filed. This white paper reviews timing, mathematical and clerical adjustments, interest and penalties, and limits on amount of imputed underpayment.



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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