The “small partnership” exception, as it is termed, one of the greatest moves toward simplification in the history of the federal income tax, has made headlines because some of the members failed to pay their shares of the income tax imposed on the farming operation.1 Some members of the group opposed to the small partnership concept have used the occasion to criticize the use of the provision enacted in 19822 as a response to the tax sheltering going on at that time. As written, the small partnership exception, by its terms, provides an avenue for many small partnerships to sidestep the increased complexity of federal partnership law added by TEFRA.