In Chief Counsel Advice 201733013 the IRS concluded there is not an exemption from filing a tax return for small partnerships under any of the below authorities:
- IRC §6031;
- IRC §6693; or
- Revenue Procedure 84-35.
IRC §6031(a) imposes the requirement that each partnership must file an annual partnership return. IRC §6698 imposes a per month penalty when the partnership fails to file a return—and for 2017 returns that penalty amount is set at $200 per month. This penalty can be waived if the failure to file is due to reasonable cause. 
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