You represent ABC partnership, a NY partnership that has 3 individual partners. In 2014, the New York State Department of Taxation and Finance (hereinafter the “Department”) selects the partnership’s 2012 tax return, as well as each individual partner’s income tax return, for audit

. The Partners of ABC come to your office to discuss the audit letter they received. Explain what you would tell your prospective clients with regard to the audit letter they received and what they can expect going forward. Would your answer change if you believed it were a criminal rather than a civil audit? Explain your answer.

Two years later, on September 15, 2016, the Department issues each partner a Notice of Deficiency. The Department determines the following:
• Partner A has an additional outstanding tax liability of $20,000 after New York State determined that he did not properly substantiate his claimed deductions
• Partner B and C are found to have an additional $50,000 in unreported income. (I purposely left the question open ended and did not provide any information about how much gross income partner A, B, & C reported on their return, so that you can explain your answer either way.)
What defenses, if any, do each individual partners have to these potential assessments? Explain.

You represent ABC partnership, a NY partnership that has 3 individual partners. In 2014, the New York State Department of Taxation and Finance (hereinafter the “Department”) selects the partnership’s 2012 tax return, as well as each individual partner’s income tax return, for audit. The Partners of ABC come to your office to discuss the audit letter they received. Explain what you would tell your prospective clients with regard to the audit letter they received and what they can expect going forward. Would your answer change if you believed it were a criminal rather than a civil audit? Explain your answer.

Paper structure should follow D-I-E Process and no references are needed because it is part of Self Learning Journal that the professor has asked us to maintain throughout the semester. Need to mainly answer 2 questions:

• Are you surprised by the results of the questionairre?
• Do you agree with its finding that you may need to develop your leadership/management potential more than your management/leadership potential?
Two years later, on September 15, 2016, the Department issues each partner a Notice of Deficiency. The Department determines the following:
• Partner A has an additional outstanding tax liability of $20,000 after New York State determined that he did not properly substantiate his claimed deductions
• Partner B and C are found to have an additional $50,000 in unreported income.

(I purposely left the question open ended and did not provide any information about how much gross income partner A, B, & C reported on their return, so that you can explain your answer either way.)
What defenses, if any, do each individual partners have to these potential assessments? Explain.
Assuming your clients want to protest the audit determinations, explain to them their rights and the audit appeals process.

I have selected the number of sources to 5. But you don’t have to strictly follow that. Use as many sources as you want. You may use any research tool you deem fit to answer the question, however, every statement of law must be accompanied by a citation to a statute or regulation.

A citation towards a CCH blurb, journal article or the like, will not be counted. Only citations to statute or regulations will be accepted.
In addition, I’m uploading a pdf file which will be very helpful to answer the questions. Use the pdf file along with other sources to complete the assignment.