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BLOG: IRS Releases Memo Concerning Access to Administrative File in TEFRA and BBA Examinations
Caplin & Drysdale

BLOG: IRS Releases Memo Concerning Access to Administrative File in TEFRA and BBA Examinations

Date: 4/20/2021

On April 14, 2021, the IRS released a memorandum clarifying that partners and partnership representatives of TEFRA or BBA partnerships are entitled to request and receive IRS administrative file records containing partnership returns and return information, including any supporting schedules, attachments, or lists which include identifying information of persons other than the requesting party.  This memorandum serves as guidance to taxpayers pending an update to the Internal Revenue Manual.

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