CPAR

[strongsilence]

Good morning!

For each of my three small partnerships, the partners are married (and there are no other partners), I advise electing out of CPAR. I advise them that without the election, the future partners would be responsible for a tax resulting from an audit in a prior year.  When I mention an audit, they get concerned.  I want them to understand CPAR so they are informed.  The partners are laypeople without much experience in tax issues.  They accept my advice.

[BobKamman]

I don't understand why most partnerships choose that form of organization in the first place.  Do you explain to them the hazards of not limiting their liability?  

If these are just de facto partnerships, husband and wife who happen to run a Mom and Pop business together and haven't had a formal agreement since their wedding day, then it really doesn't matter.  Do they want to deal with IRS on every item on the 1040, or just on the 1065?  Unlikely that an auditor would show up in either case.  And a buyer of the business would just want the assets, not the going concern.