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26 U.S.C. § 6227 — Administrative adjustment request by partnership
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** A partnership may file a request for an administrative adjustment in the amount of one or more partnership-related items for any partnership taxable year.
**(b) Adjustment** Any such adjustment under subsection (a) shall be determined and taken into account for the partnership taxable year in which the administrative adjustment request is filed—
(1) by the partnership under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof) for the partnership taxable year in which the administrative adjustment request is filed, or
(2) by the partnership and partners under rules similar to the rules of section 6226 (determined without regard to the substitution described in subsection (c)(2)(C) thereof).
In the case of an adjustment that would not result in an imputed underpayment, paragraph (1) shall not apply and paragraph (2) shall apply with appropriate adjustments.
**(c) Period of limitations** A partnership may not file such a request more than 3 years after the later of—
(1) the date on which the partnership return for such year is filed, or
(2) the last day for filing the partnership return for such year (determined without regard to extensions).
In no event may a partnership file such a request after a notice of an administrative proceeding with respect to the taxable year is mailed under section 6231.
**(d) Coordination with adjustments related to foreign tax credits** The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6227
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Source file: Laws/federal/codes/united-states-code/title-26/section-6227-administrative-adjustment-request-by-partnership--4a6b56d9cc.md
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Source location: Title 26, Chapter 63, § 6227; chapter-063-assessment.md
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**(a) In general** A partnership may file a request for an administrative adjustment in the amount of one or more partnership-related items for any partnership taxable year.
**(b) Adjustment** Any such adjustment under subsection (a) shall be determined and taken into account for the partnership taxable year in which the administrative adjustment request is filed—
(1) by the partnership under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof) for the partnership taxable year in which the administrative adjustment request is filed, or
(2) by the partnership and partners under rules similar to the rules of section 6226 (determined without regard to the substitution described in subsection (c)(2)(C) thereof).
In the case of an adjustment that would not result in an imputed underpayment, paragraph (1) shall not apply and paragraph (2) shall apply with appropriate adjustments.
**(c) Period of limitations** A partnership may not file such a request more than 3 years after the later of—
(1) the date on which the partnership return for such year is filed, or
(2) the last day for filing the partnership return for such year (determined without regard to extensions).
In no event may a partnership file such a request after a notice of an administrative proceeding with respect to the taxable year is mailed under section 6231.
**(d) Coordination with adjustments related to foreign tax credits** The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** Any adjustment to a partnership-related item shall be determined, and any tax attributable thereto shall be assessed and collected, and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to any such item shall be determined, at the partnership level, except to the extent otherwise provided in this subchapter.
**(b) Election out for certain partnerships with 100 or fewer partners, etc.**
(1) **In general** — This subchapter shall not apply with respect to any partnership for any taxable year if—
(A) the partnership elects the application of this subsection for such taxable year,
(B) for such taxable year the partnership is required to furnish 100 or fewer statements under section 6031(b) with respect to its partners,
(C) each of the partners of such partnership is an individual, a C corporation, any foreign entity that would be treated as a C corporation were it domestic, an S corporation, or an estate of a deceased partner,
(D) the election—
(i) is made with a timely filed return for such taxable year, and
(ii) includes (in the manner prescribed by the Secretary) a disclosure of the name and taxpayer identification number of each partner of such partnership, and
(E) the partnership notifies each such partner of such election in the manner prescribed by the Secretary.
(2) **Special rules relating to certain partners**
(A) *S corporation partners* — In the case of a partner that is an S corporation—
(i) the partnership shall only be treated as meeting the requirements of paragraph (1)(C) with respect to such partner if such partnership includes (in the manner prescribed by the Secretary) a disclosure of the name and taxpayer identification number of each person with
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6221
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Every partnership (as defined in section 761(a)) shall make a return for each taxable year, stating specifically the items of its gross income and the deductions allowable by subtitle A, and such other information, for the purpose of carrying out the provisions of subtitle A as the Secretary may by forms and regulations prescribe, and shall include in the return the names and addresses of the individuals who would be entitled to share in the taxable income if distributed and the amount of the distributive share of each individual.
**(b) Copies to partners** Each partnership required to file a return under subsection (a) for any partnership taxable year shall (on or before the day on which the return for such taxable year was required to be filed) furnish to each person who is a partner or who holds an interest in such partnership as a nominee for another person at any time during such taxable year a copy of such information required to be shown on such return as may be required by regulations. Information required to be furnished by the partnership under this subsection may not be amended after the due date of the return under subsection (a) to which such information relates, except—
(1) in the case of a partnership which has elected the application of section 6221(b) for the taxable year,
(2) as provided in the procedures under section 6225(c),
(3) with respect to statements under section 6226, or
(4) as otherwise provided by the Secretary.
**(c) Nominee reporting** Any person who holds an interest in a partnership as a nominee for another person—
(1) shall furnish to the partnership, in the manner prescribed by the Secretary, the name and address of such other person, and any other information for such taxable year as the Secretary may by f
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6031
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Federal law — U.S. Code and appendices · legal_authorities
Page 3540
TITLE 26—INTERNAL REVENUE CODE
§ 6227
(C) Partnership payment of tax if elected out
of subchapter
In the case of a partnership which has
elected the application of section 6221(b)
with respect to the taxable year of the part-
nership which includes the end of the re-
viewed year of the audited partnership, this
paragraph shall apply notwithstanding such
election.
(D) Audited partnership
For purposes of this paragraph, the term
‘‘audited partnership’’ means, with respect
to any partner described in subparagraph
(A), the partnership in the chain of owner-
ship originally electing the application of
this section.
(E) Treatment of trusts
The Secretary shall prescribe such rules as
may be necessary with respect to trusts
which receive a statement under subsection
(a)(2).
(c) Penalties and interest
(1) Penalties
Notwithstanding subsections (a) and (b), any
penalties, additions to tax, or additional
amount shall be determined as provided under
section 6221 and the partners of the partner-
ship for the reviewed year shall be liable for
any such penalty, addition to tax, or addi-
tional amount.
(2) Interest
In the case of an imputed underpayment
with respect to which the application of this
section is elected, or which is described in sub-
section (b)(4)(A)(ii)(I), interest shall be deter-
mined—
(A) at the partner level,
(B) from the due date of the return for the
taxable year to which the increase is attrib-
utable (determined by taking into account
any increases attributable to a change in tax
attributes for a taxable year under sub-
section (b)(2)), and
(C) at the underpayment rate under sec-
tion 6621(a)(2), determined by substituting ‘‘5
percentage points’’ for ‘‘3 percentage points’’
in subparagraph (B) thereof.
(d) Judicial r
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6227
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