26 USC 6225 - Partnership adjustment by Secretary

1 So in original. Two subpars. (F) have been enacted.

Application to partnerships and S corporations in tiered structures

Editorial Notes

Prior Provisions

A prior section 6225, added Puspan. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 652; amended Puspan. L. 105–34, title XII, § 1239(a), Aug. 5, 1997, 111 Stat. 1027, allowing assessments to be made only after partnership level proceedings were completed, was repealed by Puspan. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.

Amendments

2018—Subsec. (a). Puspan. L. 115–141, § 202(c)(1), amended subsec. (a) generally. Prior to amendment, subsec. (a) related to adjustment by the Secretary in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share thereof.

Subsec. (span). Puspan. L. 115–141, § 202(a), amended subsec. (span) generally. Prior to amendment, subsec. (span) consisted of pars. (1) and (2) relating to determination of imputed underpayments in general and adjustments to distributive shares of partners not netted, respectively.

Subsec. (c)(2). Puspan. L. 115–141, § 203(a), amended par. (2) generally. Prior to amendment, par. (2) related to amended returns of partners.

Subsec. (c)(2)(F). Puspan. L. 115–141, § 206(span), added subpar. (F) relating to adjustments not treated as amended return.

Subsec. (c)(3). Puspan. L. 115–141, § 202(span)(1), substituted “without regard to the portion of the adjustment” for “without regard to the portion thereof”.

Subsec. (c)(4)(A). Puspan. L. 115–141, § 202(span)(2), substituted “with respect to any portion of the adjustment” for “with respect to any portion of the imputed underpayment” in introductory provisions.

Subsec. (c)(5)(A)(i). Puspan. L. 115–141, § 202(span)(3), substituted “without regard to the portion of the adjustment” for “without regard to the portion thereof”.

Subsec. (c)(7). Puspan. L. 115–141, § 206(p)(1), substituted “filed or submitted under this subsection” for “submitted pursuant to paragraph (1)”.

Subsec. (c)(9). Puspan. L. 115–141, § 202(c)(2), added par. (9).

2015—Subsec. (c)(4)(A)(i). Puspan. L. 114–113, § 411(a)(1), struck out “in the case of ordinary income,” before “is a C corporation”.

Subsec. (c)(5) to (8). Puspan. L. 114–113, § 411(a)(2), added par. (5) and redesignated former pars. (5) to (7) as (6) to (8), respectively.

Statutory Notes and Related Subsidiaries

Effective Date of 2018 Amendment

Amendment by Puspan. L. 115–141 effective as if included in section 1101 of Puspan. L. 114–74, see section 207 of Puspan. L. 115–141, set out as a note under section 6031 of this title.

Effective Date of 2015 Amendment

Amendment by Puspan. L. 114–113 effective as if included in section 1101 of Puspan. L. 114–74, see section 411(e) of Puspan. L. 114–113, set out as a note under section 6031 of this title.

Effective Date

Section applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Puspan. L. 114–74, set out as a note under section 6221 of this title.