Darryll K. Jones (Pittsburgh) has published Don’t Burn the Partnership Audit Technique Guide, 108 Tax Notes 829 (Aug. 15, 2005), also available on the Tax Analysts web site as Doc 2005-16589, 2005 TNT 157-27.  Here is part of the opening:

The IRS Partnership Audit Technique Guide will probably not sell like Nietzsche or even a J.K. Rowling novel, but it shouldn’t be used for kindling just yet. It was originally authored in December 2002, and then revised and reissued on June 10, 2005. Ironically, the revised edition contains several sections that are or soon will be outdated. The grant of capital or profit interests to service partners, mandatory basis adjustments, built-in loss property, disguised sales of partnership interests, and liabilities are some of the important areas about which the newly issued guide is already obsolete. Still, the guide is quite useful in many other aspects. I’ve often wondered, for example, how firms and the IRS go about the prodigious task of training new associates in partnership tax. I hope my students leave my class with an understanding of the purpose and jargon of subchapter K, if nothing else. Purpose and jargon allow us to put things in context and proceed to application and, for some, manipulation. But it takes more than one semester of learning about purpose and jargon to fully or even tentatively grasp subchapter K and its applications. And yet associates and examiners can’t afford the time it would take to leisurely stroll through the sub K thicket the way professors can. They have to run with the bulls immediately or suffer the consequences.