47672311_cks_and_traps_to_watch_out_for__TEFRA
[Non-TEFRA] An investor’s agreement to pass-thru entity changes may not be final. The investor may file a claim for refund and petition District Court or the United States Court of Federal Claims. [TEFRA] 
A partner's agreement to changes in partnership items is final. The partners cannot file a claim for refund.
Elections & Extensions - Tricks and traps to watch out for
TEFRA