Partnership Representative for IRS - 1065, page 3
I believe Ira's explanation needs clarification. For clubs that opt out, the IRS will audit the partnership and then provide a schedule of each partner's share the partnership audit adjustments. The IRS can't make any adjustments to a partner's tax return without first auditing the partnership.
On Wednesday, February 19, 2020 ira smilovitz via bivio.com <email@example.com> wrote:
There is no partnership representative for clubs that have opted out of the Centralized Partnership Audit Regime. If the IRS wants to audit an "opt-out" club, it must do so by auditing the personal returns of each of the partners.
Ira Smilovitz, EA