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An IRA owner holds a significant partnership interest in his account that is generating nearly $100K in UBTI annually. He is going to starting filing the 990-T (he will have it prepared, the IRA trustee files it), however he is concerned that if he starts filing now, IRS may ask about prior years.

Does anyone have any experience with IRS and 990-Ts and whether or not filing a 2016 return will generate an inquiry for 2015 and prior years.

As an aside, the UBTI was much much less in prior years, but likely over the $1K threshold. A refinancing increased the leverage in the partnership.

I carry stuff uphill for others who get all the glory.

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