A Glance Into Travel


"We want every educator, school staff member, child-care worker to receive at least one shot by the end of the month of March," Biden said. Biden's directive is meant to reassure anxious teachers who have clashed with the administration over recent guidance from the Centers for Disease Control and Prevention, which said that teacher vaccinations should not be considered a prerequisite for schools to reopen. In a clear signal of solidarity, Cardona and Dr. Biden were joined yesterday by the heads of the nation's largest teachers unions, Becky Pringle of the National Education Association and Randi Weingarten of the American Federation of Teachers. CDC Offers Clearest Guidance Yet For Reopening Schools Cardona is now the face of President Biden's school reopening push. In addition to touting Biden's vaccination directive, he's also been talking up Democrats' COVID relief bill, which would send $130 billion dollars to K-12 schools, and pledged to convene a national school reopening summit later this month. Early Thursday, Cardona spoke with Morning Edition's Rachel Martin. Below is their interview, edited for clarity. Q: President Biden challenged states to give a vaccine shot to every educator and school staff member before the end of this month. How do you compel states to make that happen? I applaud that charge. First of all, it is our shared goal to reopen schools safely and quickly. You know, I haven't met an educator that doesn't agree that students learn best in school, and they really want our students to be learning in schools. So it's just a matter of implementing it in a manner that is expeditious and is aimed at really reopening schools quickly. Q: Although the CDC says vaccinating teachers is not a requirement for opening schools safely. You're right, Rachel. I can tell you from my experience in Connecticut, where over 90 percent of the students have an opportunity to learn in person today, and many students were learning in person before the vaccine was even approved.


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TEFRA was widely credited with helping control the widespread partnership tax shelters of the early 1980s while providing due process to partners. The steady increase in size, scale and numbers of partnerships began to undercut the effectiveness of the TEFRA partnership regime, as the IRS struggled to trace through multiple tiers of entities to identify, assess, and collect from large numbers of individual and corporate partners. The partnership audit coverage rate has perennially hovered at or below 0.05%, and the no-change rate (that is, returns examined without any proposed adjustments) has been about 50%. These partnership statistics compare unfavorably to more general IRS enforcement numbers, which have also declined over the past several years. In 2013, Congress requested that the Government Accountability Office (GAO) investigate the IRS’s approach to auditing large partnerships under the TEFRA procedures. The GAO report concluded that the IRS audits few large partnerships, most audits resulted in no change to the partnership’s return, and when there were changes, the aggregate amount of adjustments was small. See U.S. Gov’t Accountability Office, Large Partnerships: With Growing Number of Partnerships, IRS Needs to Improve Audit Efficiency, 13 (2014) (GAO-14-732). The GAO report prompted multiple legislative proposals seeking to address the shortcomings of the TEFRA regime. Congress enacted the Bipartisan Budget Act of 2015 to repeal TEFRA and replace it with the BBA centralized partnership audit regime, generally effective for taxable years beginning in 2018. Like TEFRA, the BBA provides for the determination of partnership adjustments at the partnership level, but unlike my link TEFRA, it also empowers the IRS to assess and collect tax attributable to those adjustments from the partnership itself. The partnership may “push” the adjustments out to its partners, but it is the partners rather than the IRS who must pass through the adjustments and determine the resulting tax liability, thereby alleviating some of the administrative burdens created for the IRS by the TEFRA rules. With these new rules, Congress gave the IRS several structural advantages. For instance, under the BBA, the default is that the audited partnership is liable for any imputed underpayment resulting from adjustments to partnership-related items. In calculating the imputed underpayment, adjustments that are favorable often cannot be netted against unfavorable adjustments, and they must be taken into account in the adjustment year. The partnership’s liability for an imputed underpayment is calculated by applying the highest applicable rate for the reviewed year (either the individual or the corporate rate, whichever is higher) to the combined adjustments.