47672311_cks_and_traps_to_watch_out_for__TEFRA
[Non-TEFRA] If agreement cannot be reached, the IRS sends a Statutory Notice of Deficiency to the investor. If the adjustments flowing from the entity do not produce a deficiency, the deficiency notice cannot be sent. [TEFRA] 
If agreement cannot be reached, the IRS sends a Notice of Final Partnership Administrative Adjustments to the TMP and the partners . The adjustment does not have to produce a deficiency in order for the Tax Court to gain jurisdiction.
Elections & Extensions - Tricks and traps to watch out for
TEFRA