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26 U.S.C. § 6231 — Notice of proceedings and adjustment
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** The Secretary shall mail to the partnership and the partnership representative—
(1) notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any partnership-related item for any partnership taxable year, or any partner’s distributive share thereof,
(2) notice of any proposed partnership adjustment resulting from such proceeding, and
(3) notice of any final partnership adjustment resulting from such proceeding.
Any notice of a final partnership adjustment shall be sufficient if mailed to the last known address of the partnership representative or the partnership (even if the partnership has terminated its existence). The first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a partnership under section 6227.
**(b) Timing of notices**
(1) **Notice of proposed partnership adjustment** — Any notice of a proposed partnership adjustment shall not be mailed later than the date determined under section 6235 (determined without regard to paragraphs (2) and (3) of subsection (a) thereof).
(2) **Notice of final partnership adjustment**
(A) *In general* — Except to the extent that the partnership elects to waive the application of this subparagraph, any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed.
(B) *Statute of limitations on adjustment* — For the period of limitations on making adjustments, see section 6235.
**(c) Further notices restricted** If the Secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section 6234 with respect
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Source location: Title 26, Chapter 63, § 6231; chapter-063-assessment.md
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**(a) In general** The Secretary shall mail to the partnership and the partnership representative—
(1) notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any partnership-related item for any partnership taxable year, or any partner’s distributive share thereof,
(2) notice of any proposed partnership adjustment resulting from such proceeding, and
(3) notice of any final partnership adjustment resulting from such proceeding.
Any notice of a final partnership adjustment shall be sufficient if mailed to the last known address of the partnership representative or the partnership (even if the partnership has terminated its existence). The first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a partnership under section 6227.
**(b) Timing of notices**
(1) **Notice of proposed partnership adjustment** — Any notice of a proposed partnership adjustment shall not be mailed later than the date determined under section 6235 (determined without regard to paragraphs (2) and (3) of subsection (a) thereof).
(2) **Notice of final partnership adjustment**
(A) *In general* — Except to the extent that the partnership elects to waive the application of this subparagraph, any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed.
(B) *Statute of limitations on adjustment* — For the period of limitations on making adjustments, see section 6235.
**(c) Further notices restricted** If the Secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section 6234 with respect to such notice, in the absence of a showing of fraud, malfeasance, or misrepresentation of a material fact, the Secretary shall not mail another such notice to such partnership with respect to such taxable year.
**(d) Authority to rescind notice with partnership consent** The Secretary may, with the consent of the partnership, rescind any notice of a partnership adjustment mailed to such partnership. Any notice so rescinded shall not be treated as a notice of a partnership adjustment for purposes of this subchapter, and the taxpayer shall have no right to bring a proceeding under section 6234 with respect to such notice.
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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
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Requirement of return** Any United States person, except to the extent otherwise provided by regulations—
(1) who acquires any interest in a foreign partnership,
(2) who disposes of any portion of his interest in a foreign partnership, or
(3) whose proportional interest in a foreign partnership changes substantially,
shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.
**(b) Form and contents of return** Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.
**(c) Time for filing return** Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.
**(d) 10-percent interest** For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).
**(e) Cross reference** For provisions relating to penalties for violations of this section, see sections 6679 and 7203.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6046A
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Federal law — U.S. Code and appendices · legal_authorities
Page 3541
TITLE 26—INTERNAL REVENUE CODE
§ 6231
(2) by the partnership and partners under
rules similar to the rules of section 6226 (de-
termined without regard to the substitution
described in subsection (c)(2)(C) thereof).
In the case of an adjustment that would not re-
sult 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 re-
turn for such year (determined without regard
to extensions).
In no event may a partnership file such a re-
quest after a notice of an administrative pro-
ceeding with respect to the taxable year is
mailed under section 6231.
(d) Coordination with adjustments related to for-
eign tax credits
The Secretary shall issue regulations or other
guidance which provide for the proper coordina-
tion of this section and section 905(c).
(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov.
2, 2015, 129 Stat. 631; amended Pub. L. 115–141,
div. U, title II, §§ 201(c)(5), 206(f), (p)(2), (3), Mar.
23, 2018, 132 Stat. 1173, 1179, 1182.)
Editorial Notes
PRIOR PROVISIONS
Prior sections 6227 to 6230 were repealed by Pub. L.
114–74, title XI, § 1101(a), (g), Nov. 2, 2015, 129 Stat. 625,
638, applicable to returns filed for partnership taxable
years beginning after Dec. 31, 2017.
Section 6227, added Pub. L. 97–248, title IV, § 402(a),
Sept. 3, 1982, 96 Stat. 655; amended Pub. L. 105–34, title
XII, §§ 1236(a), 1243(a), Aug. 5, 1997, 111 Stat. 1025, 1029;
Pub. L. 107–147, title IV, § 417(19)(A), Mar. 9, 2002, 116
Stat. 56, related to administrative adjustm
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6231
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