Skip to Main Content

Mark Allison and Charles Ruchelman Comment: Record-Low Audit Rates Could Reverse as IRS Alters Exams

February 27, 2017, Bloomberg BNA

Taxpayers may see examination rates for all businesses rise in the coming years as the IRS begins using more efficient procedures amid auditor shortages.

The number of large-corporation audits may not increase drastically, but the IRS will be able to be more efficient with the audits they are doing, and the government can raise more revenue and deter more tax avoidance, said Mark D. Allison, a member at Caplin & Drysdale, Chartered specializing in tax controversy.

. . .

Partnerships, especially bigger entities audited by LB&I, will also likely face audits that look beyond top-line taxable income to more specific allocations among partners as the IRS improves its systems to track investors, [said a tax practitioner].

To do this, however, the IRS will likely need to train more auditors about the intricacies of the partnership rules, which differ greatly from corporate tax. The audit process is slowed down when IRS agents have to continually go back to specialists to get answers on a complex partnership issue, said Charles Ruchelman, a member at Caplin & Drysdale who focuses on partnership controversy issues.

“The challenge is for the IRS to get started on a partnership audit earlier,” Ruchelman said. “They tend to have more delays than on the corporate side of things.”

For more information on the new partnership audit rule, please visit

To read the full article, please visit Bloomberg BNA’s website (subscription required).

Excerpt taken from the article “Record-Low Audit Rates Could Reverse as IRS Alters Exams” by Laura Davison and Colleen Murphy for Bloomberg BNA.


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2022 Caplin & Drysdale, Chartered
All Rights Reserved.