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26 U.S.C. § 6234 — Judicial review of partnership adjustment

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

26 U.S.C. § 6234 — Judicial review of partnership adjustment

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Source location: Title 26, Chapter 63, § 6234; chapter-063-assessment.md

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**(a) In general** Within 90 days after the date on which a notice of a final partnership adjustment is mailed under section 6231 with respect to any partnership taxable year, the partnership may file a petition for a readjustment for such taxable year with— (1) the Tax Court, (2) the district court of the United States for the district in which the partnership’s principal place of business is located, or (3) the Court of Federal Claims. **(b) Jurisdictional requirement for bringing action in district court or Court of Federal Claims** (1) **In general** — A readjustment petition under this section may be filed in a district court of the United States or the Court of Federal Claims only if the partnership filing the petition deposits with the Secretary, on or before the date the petition is filed, the amount of (as of the date of the filing of the petition) the imputed underpayment, penalties, additions to tax, and additional amounts with respect to such imputed underpayment if the partnership adjustment was made as provided by the notice of final partnership adjustment. The court may by order provide that the jurisdictional requirements of this paragraph are satisfied where there has been a good faith attempt to satisfy such requirement and any shortfall of the amount required to be deposited is timely corrected. (2) **Interest payable** — Any amount deposited under paragraph (1), while deposited, shall not be treated as a payment of tax for purposes of this title (other than chapter 67). **(c) Scope of judicial review** A court with which a petition is filed in accordance with this section shall have jurisdiction to determine all partnership-related items for the partnership taxable year to which the notice of final partnership adjustment relates, the proper allocation of such items among the partners, and the applicability of any penalty, addition to tax, or additional amount for which the partnership may be liable under this subchapter. **(d) Determination of court reviewable** Any determination by a court under this section shall have the force and effect of a decision of the Tax Court or a final judgment or decree of the district court or the Court of Federal Claims, as the case may be, and shall be reviewable as such. The date of any such determination shall be treated as being the date of the court’s order entering the decision. **(e) Effect of decision dismissing action** If an action brought under this section is dismissed other than by reason of a rescission under section 6231(c),11 See References in Text note below. the decision of the court dismissing the action shall be considered as its decision that the notice of final partnership adjustment is correct, and an appropriate order shall be entered in the records of the court.

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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

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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

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

26 U.S.C. § 6211 — Definition of a deficiency

**(a) In general** For purposes of this title in the case of income, estate, and gift taxes imposed by subtitles A and B and excise taxes imposed by chapters 41, 42, 43, and 44 the term “deficiency” means the amount by which the tax imposed by subtitle A or B, or chapter 41, 42, 43, or 44 exceeds the excess of— (1) the sum of (A) the amount shown as the tax by the taxpayer upon his return, if a return was made by the taxpayer and an amount was shown as the tax by the taxpayer thereon, plus (B) the amounts previously assessed (or collected without assessment) as a deficiency, over— (2) the amount of rebates, as defined in subsection (b)(2), made. **(b) Rules for application of subsection (a)** For purposes of this section— (1) The tax imposed by subtitle A and the tax shown on the return shall both be determined without regard to payments on account of estimated tax, without regard to the credit under section 31, without regard to the credit under section 33, and without regard to any credits resulting from the collection of amounts assessed under section 6851 or 6852 (relating to termination assessments). (2) The term “rebate” means so much of an abatement, credit, refund, or other repayment, as was made on the ground that the tax imposed by subtitle A or B or chapter 41, 42, 43, or 44 was less than the excess of the amount specified in subsection (a)(1) over the rebates previously made. (3) The computation by the Secretary, pursuant to section 6014, of the tax imposed by chapter 1 shall be considered as having been made by the taxpayer and the tax so computed considered as shown by the taxpayer upon his return. (4) For purposes of subsection (a)— (A) any excess of the sum of the credits allowable under sections 21 by reason of subsection (g) thereof, 24

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

28 U.S.C. § 1346 — United States as defendant

**(a)** The district courts shall have original jurisdiction, concurrent with the United States Court of Federal Claims, of: (1) Any civil action against the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, or any penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected under the internal-revenue laws; (2) Any other civil action or claim against the United States, not exceeding $10,000 in amount, founded either upon the Constitution, or any Act of Congress, or any regulation of an executive department, or upon any express or implied contract with the United States, or for liquidated or unliquidated damages in cases not sounding in tort, except that the district courts shall not have jurisdiction of any civil action or claim against the United States founded upon any express or implied contract with the United States or for liquidated or unliquidated damages in cases not sounding in tort which are subject to sections 7104(b)(1) and 7107(a)(1) of title 41. For the purpose of this paragraph, an express or implied contract with the Army and Air Force Exchange Service, Navy Exchanges, Marine Corps Exchanges, Coast Guard Exchanges, or Exchange Councils of the National Aeronautics and Space Administration shall be considered an express or implied contract with the United States. **(b)** (1) Subject to the provisions of chapter 171 of this title, the district courts, together with the United States District Court for the District of the Canal Zone and the District Court of the Virgin Islands, shall have exclusive jurisdiction of civil actions on claims against the United States, for money damages, accruing on and afte

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

28 U.S.C. § 1508 — Jurisdiction for certain partnership proceedings

The Court of Federal Claims shall have jurisdiction to hear and to render judgment upon any petition under section 6226 or 6228(a) of the Internal Revenue Code of 1986.

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

26 U.S.C. § 6234 — Judicial review of partnership adjustment

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

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