In both cases the court found that the assessment was attributable to a partnership item, and thus the court did not have jurisdiction to decide the case under TEFRA
. In both these cases, the taxpayer may have been better off taking the case to the Tax Court.
, small partnerships mean any partnerships that have 10 or fewer partners and whose partners consist exclusively of individuals, estates and C corporations.
Also, under TEFRA
, unless the partnership elected to be taxed at the entity level, the IRS had to pass audit adjustments through to the ultimate partners.
Due to the complexity of these procedural rules, the IRS can misapply TEFRA
to the taxpayer's advantage.
The structure of the PFA, local government oversight, the project evaluation process, and the TEFRA
approval requirement promote accountability and transparency for each financing.
(CCH) 1622 (2009) (stating that TEFRA
"has created problems of judicial administration in the case at hand and similar pending cases that will not be resolved by recently proposed regulations.").
DRGs were established under the Tax Equity and Fiscal Responsibility Act (TEFRA
) legislation of 1983 (8).
In an attempt to increase enrollment in 1982, the Tax Equity and Fiscal Responsibility Act (TEFRA
) dictated that the HMOs were to be compensated at 95 percent per capita fee-for-service (FFS) costs with the expectation that the efficiencies of HMOs would save the government 5 percent.
The Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA
") effectively began to take the middle class out of the federal transfer tax system by the adoption of a series of reforms, including a $10,000 annual exclusion, an unlimited marital deduction and a phased-in unified tax credit equivalent to a $600,000 exemption.
Many of the TEFRA
provisions affected the corporate sector.