§ 6227 Administrative adjustment request by partnership

OLRC 119-134 · eCFR 2026-10-19 · 5 regs · 1 amending Acts · cited by 6 sections

Enacted 2015 · Pub. L. 114-74 Amended · 1 Acts

Prior provisions 5
  • Prior sections 6227 to 6230 were repealed by Pub.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 adjustment requests.
  • Section 6228, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 656; amended Pub. L. 97–448, title III, § 306(c)(1)(B), Jan. 12, 1983, 96 Stat. 2406; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 107–147, title IV, § 417(19)(B), Mar. 9, 2002, 116 Stat. 56, related to judicial review where administrative adjustment request is not allowed in full.
  • Section 6229, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 659; amended Pub. L. 99–514, title XVIII, § 1875(d)(1), Oct. 22, 1986, 100 Stat. 2896; Pub. L. 100–647, title I, § 1018(o)(3), Nov. 10, 1988, 102 Stat. 3585; Pub. L. 105–34, title XII, §§ 1233(a)–(c), 1235(a), Aug. 5, 1997, 111 Stat. 1023, 1024; Pub. L. 107–147, title IV, § 416(d)(1)(B), Mar. 9, 2002, 116 Stat. 55; Pub. L. 111–147, title V, § 513(a)(2)(B), Mar. 18, 2010, 124 Stat. 112, related to period of limitations for making assessments.
  • Section 6230, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 660; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(A), July 18, 1984, 98 Stat. 964; Pub. L. 99–514, title XVIII, § 1875(d)(2)(A), Oct. 22, 1986, 100 Stat. 2896; Pub. L. 100–647, title I, § 1018(o)(1), Nov. 10, 1988, 102 Stat. 3584; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 105–34, title XII, §§ 1237(a)–(c)(1), 1238(b)(2)–(6), 1239(c)(1), Aug. 5, 1997, 111 Stat. 1025–1028; Pub. L. 105–206, title III, § 3201(e)(2), July 22, 1998, 112 Stat. 740; Pub. L. 110–172, § 11(a)(36), Dec. 29, 2007, 121 Stat. 2487, related to additional administrative provisions.
Connections Cited by 6 · Cites 4

(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.

Amended 2018
  • 2018 Pub. L. 115-141 Pub. L. 115–141, § 201(c)(5), substituted “partnership-related items” for “items of income, gain, loss, deduction, or credit of the partnership”.
Cited by 1

    (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—

    Amended 2018
    • 2018 Pub. L. 115-141 Pub. L. 115–141, § 206(p)(2), substituted “is filed” for “is made” in introductory provisions and in par. (1).

    (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

    Amended 2018
    • 2018 Pub. L. 115-141 Pub. L. 115–141, § 206(p)(3), which directed substitution of “paragraphs (2), (7), and (9)” for “paragraphs (2), (6), and (7)”, was executed by making the substitution for “paragraphs (2), (6) and (7)” to reflect the probable intent of Congress.
    Cited by 3

      (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).

      Cited by 1

        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).

        Cited by 1

          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).

          § 301.6227(d)-1 Administrative adjustment request filed on behalf of a partner.
          Amended 2018