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In rejecting Nault's argument, the district court also noted that results of unified partnership audit procedures under the Tax Equity and Fiscal Responsibility Act could not be litigated at the partner level. These two IRS Chief Counsel releases conclude that partnership withholding taxes on income allocated to foreign persons are "partnership items" to be determined at the partnership level under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and hence are subject to the uniform partnership audit proceedings prescribed by Secs. Municipal bond and coupon volume has been declining since the passage of the Tax Equity and Fiscal Responsibility Act of 1982, which effectively eliminated the issuance of municipal bearer bonds. |
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