IRS Guidance on Disregarded Entities, TEFRA Rules, and Partnership Liability

IRS Guidance on Disregarded Entities, TEFRA Rules, and Partnership Liability The passage details internal IRS interpretations of tax collection and audit rules for disregarded entities and small partnerships. It contains no references to influential public figures, political actors, or controversial financial flows, limiting its investigative usefulness to niche tax practice matters. Key insights: IRS can levy on a sole member's interest in an LLC despite the LLC being a disregarded entity.; State law determines property interests for tax collection purposes.; TEFRA audit rules apply at the partnership level, with a small partnership exception for entities with ten or fewer partners.