Arkansas Legal Resource Navigator

26 U.S.C. § 6233 — Interest and penalties

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6233 — Interest and penalties

**(a) Interest and penalties determined from reviewed year** (1) **In general** — Except to the extent provided in section 6226(c), in the case of a partnership adjustment for a reviewed year— (A) interest shall be computed under paragraph (2), and (B) the partnership shall be liable for any penalty, addition to tax, or additional amount as provided in paragraph (3). (2) **Determination of amount of interest** — The interest computed under this paragraph with respect to any partnership adjustment is the interest which would be determined under chapter 67 for the period beginning on the day after the return due date for the reviewed year and ending on the return due date for the adjustment year (or, if earlier, the date payment of the imputed underpayment is made). Proper adjustments in the amount determined under the preceding sentence shall be made for adjustments required for partnership taxable years after the reviewed year and before the adjustment year by reason of such partnership adjustment. (3) **Penalties** — Any penalty, addition to tax, or additional amount shall be determined at the partnership level as if such partnership had been an individual subject to tax under chapter 1 for the reviewed year and the imputed underpayment were an actual underpayment (or understatement) for such year. **(b) Interest and penalties with respect to adjustment year return** (1) **In general** — In the case of any failure to pay an imputed underpayment on the date prescribed therefor, the partnership shall be liable— (A) for interest as determined under paragraph (2), and (B) for any penalty, addition to tax, or additional amount as determined under paragraph (3). (2) **Interest** — Interest determined under this paragraph is the interest that would be determ

Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6233

Stored review status: release_metadata_unconfirmed. A text match is a research starting point; applicability is not established.

Original supplied file — preserved unchanged

Download original Markdown file

File SHA-256: 55a895d70d8a1218d068a1f549d98ebb798c477d5eac839fc26f326ac9d7a731. The original may include catalog metadata, neighboring provisions, or embedded records outside this collection's scope. Search shows only the selected federal record. Historical editions and unverified snapshots are not a statement of current law.

Authority boundary: historical or unconfirmed source not current law verified.

Open the recorded source website ↗

Record provenance

Stable record: federal_law:legal_authorities:record_usc_c74df95f1f5964d53d893073
Source file: Laws/federal/codes/united-states-code/title-26/section-6233-interest-and-penalties--b930fbbd80.md
Pages: Not recorded – Not recorded
Passage SHA-256: 62728a3a9f2469d46642ffaa5dba689ed79ee5ad065fcdd065493c3ec32f7f4b

Source location: Title 26, Chapter 63, § 6233; chapter-063-assessment.md

Stored source content

**(a) Interest and penalties determined from reviewed year** (1) **In general** — Except to the extent provided in section 6226(c), in the case of a partnership adjustment for a reviewed year— (A) interest shall be computed under paragraph (2), and (B) the partnership shall be liable for any penalty, addition to tax, or additional amount as provided in paragraph (3). (2) **Determination of amount of interest** — The interest computed under this paragraph with respect to any partnership adjustment is the interest which would be determined under chapter 67 for the period beginning on the day after the return due date for the reviewed year and ending on the return due date for the adjustment year (or, if earlier, the date payment of the imputed underpayment is made). Proper adjustments in the amount determined under the preceding sentence shall be made for adjustments required for partnership taxable years after the reviewed year and before the adjustment year by reason of such partnership adjustment. (3) **Penalties** — Any penalty, addition to tax, or additional amount shall be determined at the partnership level as if such partnership had been an individual subject to tax under chapter 1 for the reviewed year and the imputed underpayment were an actual underpayment (or understatement) for such year. **(b) Interest and penalties with respect to adjustment year return** (1) **In general** — In the case of any failure to pay an imputed underpayment on the date prescribed therefor, the partnership shall be liable— (A) for interest as determined under paragraph (2), and (B) for any penalty, addition to tax, or additional amount as determined under paragraph (3). (2) **Interest** — Interest determined under this paragraph is the interest that would be determined by treating the imputed underpayment as an underpayment of tax imposed in the adjustment year. (3) **Penalties** — Penalties, additions to tax, or additional amounts determined under this paragraph are the penalties, additions to tax, or additional amounts that would be determined— (A) by applying section 6651(a)(2) to such failure to pay, and (B) by treating the imputed underpayment as an underpayment of tax for purposes of part II of subchapter A of chapter 68. **(c) Deposit to suspend interest** For rules allowing deposits to suspend running of interest on potential underpayments, see section 6603.

Cross-references

Connections may be documented source relationships, shared citations or nearby passages. Each explains its basis; a connection alone does not establish applicability to your situation.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6221 — Determination at partnership level

**(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

Stored review status: release_metadata_unconfirmed. Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6031 — Return of partnership income

**(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

Stored review status: release_metadata_unconfirmed. Explicit cross-reference supplied in source Markdown; currentness and applicability require review.

Federal law — U.S. Code and appendices · legal_authorities

26 U.S.C. § 6233 — Interest and penalties

Page 3544 TITLE 26—INTERNAL REVENUE CODE § 6233 exceptions, see section 1101(g) of Pub. L. 114–74, set out as a note under section 6221 of this title. § 6233. Interest and penalties (a) Interest and penalties determined from re- viewed year (1) In general Except to the extent provided in section 6226(c), in the case of a partnership adjustment for a reviewed year— (A) interest shall be computed under para- graph (2), and (B) the partnership shall be liable for any penalty, addition to tax, or additional amount as provided in paragraph (3). (2) Determination of amount of interest The interest computed under this paragraph with respect to any partnership adjustment is the interest which would be determined under chapter 67 for the period beginning on the day after the return due date for the reviewed year and ending on the return due date for the ad- justment year (or, if earlier, the date payment of the imputed underpayment is made). Proper adjustments in the amount determined under the preceding sentence shall be made for ad- justments required for partnership taxable years after the reviewed year and before the adjustment year by reason of such partnership adjustment. (3) Penalties Any penalty, addition to tax, or additional amount shall be determined at the partnership level as if such partnership had been an indi- vidual subject to tax under chapter 1 for the reviewed year and the imputed underpayment were an actual underpayment (or understate- ment) for such year. (b) Interest and penalties with respect to adjust- ment year return (1) In general In the case of any failure to pay an imputed underpayment on the date prescribed therefor, the partnership shall be liable— (A) for interest as determined under para- graph (2), and (B) for

Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6233

Stored review status: historical_2024_not_currentness_verified. Same stored citation; legal effect and authority still require review.