Re: Latham & Watkins: Large Partnership Audits in the Oil & Gas Industry
From the perspective of the IRS, the money appears still to be in C corps, not MLP's. L&W's slide show says IRS got $160M out of 84 MLP audits and $16B out of their C corp audits.
If you are an IRS auditor, you want to be assigned to those juicy C Corp audits--the organizations are comparatively simple, the law and the regs are more settled and your odds are better. I think MLPs will continue to be a backwater area for the IRS, absent any major changes in the Code.