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Kate Kraus talks with Tax Notes about partners filing amended returns under the new partnership audit rules. Such partners will be required to pay tax before having an opportunity to litigate the tax dispute in Tax Court, and they may need to file protective refund claims in order to preserve their right to a refund. In addition, when filing an amended return and paying the associated taxes and penalties, a partner cannot take into account his or her reasonable cause and good faith. Instead, the partner must pay the full amount of the penalty and then raise a reasonable cause and good faith defense in a refund proceeding. Also, although refunds are available when a partner files an amended return, refunds are not available under the pull-in method.
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