Billy Long is now officially the 51st Commissioner of the Internal Revenue Service. Long was confirmed by the Senate on June 12, and was sworn in a few days later on June 16, 2025. Long told employees he plans to develop a more taxpayer-friendly agency by transforming the culture at the IRS during his tenure. “In my first 90 days I plan to ask you, my employee partners, to help me develop a new culture here. I’m big on culture, and I’m anxious to develop one that makes your lives and the taxpayers’ lives better,” Long wrote in a message…

Partnerships are an enigma under federal tax law. Although the partnership files an annual income tax return (i.e., Form 1065), the partners report their allocable share of the partnership’s tax items on their income tax returns (e.g., Form 1040). Due to the complexity inherent in partnership income tax reporting, Congress has historically struggled in attempting to find an appropriate examination tool to provide to the IRS to audit partnerships. After more than three decades under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Congress changed the partnership audit and collection rules through passage of the Bipartisan Budget Act…