Jasen D. Hanson is a shareholder in the Tax Controversy and Litigation Group at Chamberlain Hrdlicka in Atlanta. He helps high-net-worth individuals and closely held family entities resolve issues before the Internal Revenue Service and Department of Justice – Tax Division, from examination through appellate court review.
Six years of the Centralized Partnership Audit Regime have elucidated a central understanding: the provisions present plenty of potential pitfalls for partnerships, partnership representatives and the partners.