§6221. Determination at partnership level — Inbound Citations
26 U.S.C. § 6221
Cited by 4 provisions in release 119-102.
Citations to 26 U.S.C. § 6221 as a whole
-
(d) For rules relating to procedures for determining the tax treatment of partnership items see subchapter C of chapter 63 (section 6221 and following).
-
(1) Notwithstanding subsections (a) and (b), any penalties, additions to tax, or additional amount shall be determined as provided under section 6221 and the partners of the partnership for the reviewed year shall be liable for any such penalty, addition to tax, or additional amount.
Citations to §6221(b)
-
(1) in the case of a partnership which has elected the application of section 6221(b) for the taxable year,
-
(C) In the case of a partnership which has elected the application of section 6221(b) with respect to the taxable year of the partnership which includes the end of the reviewed year of the audited partnership, this paragraph shall apply notwithstanding such election.