Appeals Pass Through Entity Handbook – IRM Section 8.19.1 Procedures and Authorities

Course Description:

The Appeals Pass-Through Entity Handbook describes the special considerations that must be taken into account in resolving tax controversies of pass-through entities.  Subsection 8.19.1 focuses on TEFRA (The Tax Equity and Fiscal Responsibility Act of 1982), partnerships, disregarded entities, and limited liability companies (LLCs).

Learning Objectives:

Upon successful completion of this course, participants will be able to:

• Learn the difference between Tefra and non-Tefra procedures
• Define Pass-through entity
• Know the procedures involved in electing large partnerships
• Learn about limited liability companies (LLCs)
• Learn about check-the-box regulations
• Have a good understanding about the procedures and authorities of appeals associated with pass-through entities.