irs.gov/…/irs-announces-sweeping-effort-to-restor…

The complex structures and tax issues present in large partnerships require a focused approach to best identify the highest risk issues and apply resources accordingly. In 2021, the IRS launched the first stage of its Large Partnership Compliance (LPC) program with examinations of some of the largest and most complex partnership returns in the filing population. The IRS is now expanding the LPC program to additional large partnerships…By the end of the month, the IRS will open examinations of 75 of the largest partnerships in the U.S. that represent a cross section of industries including hedge funds, real estate investment partnerships, publicly traded partnerships, large law firms and other industries. On average, these partnerships each have more than $10 billion in assets.

Believe me when I tell you a partnership with $10b assets is insane. Auditing that is extremely labor intensive and requires a ton of highly specialized skills and that all requires resources.

There’s really nothing left to argue here so please just take this at face value and move on.