In a preliminary report from the United States Government Accountability Office (GAO) it is shown that the IRS is currently conducting a tax audit in respect of only around one percent of the largest partnerships in the US.  The GAO report suggests that the IRS is concentrating on partnerships that have 100 or more partners, and that possess assets exceeding USD 100m.

The GAO report explains that between 2002 and 2011 the number of US businesses taking the form of large partnerships saw a 200 percent increase. However despite this increase the IRS conducted field audits of only 0.8 percent of these enterprises in 2012.