§6226. Alternative to payment of imputed underpayment by partnership — Inbound Citations
26 U.S.C. § 6226
Cited by 13 provisions in release 119-102.
Citations to 26 U.S.C. § 6226 as a whole
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(3) with respect to statements under section 6226, or
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(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).
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(10) Notwithstanding section 6011(e), the Secretary may require that anything required to be filed or submitted under section 6225(c), or to be furnished to or filed with the Secretary under section 6226, be so filed, submitted, or furnished by magnetic media or in other machine-readable form.
Citations to §6226(a)(2)
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(JJ) section 6226(a)(2) (relating to statements relating to alternative to payment of imputed underpayment by partnership) or under any other provision of this title which provides for the application of rules similar to such section,
Citations to §6226(b)(4)(A)
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(i) In the case of any partnership any partner of which is a partnership, subparagraph (A) or (B) may apply with respect to any partner (hereafter in this subparagraph referred to as the “relevant partner”) in the chain of ownership of such partnerships if—(I) such information as the Secretary may require is furnished to the Secretary for purposes of carrying out this paragraph with respect to such partnerships (including any information the Secretary may require with respect to any chain of ownership of the relevant partner), and(II) to such extent as the Secretary may require, each partnership in the chain of ownership between the relevant partner and the audited partnership satisfies the requirements of subparagraph (A) or (B).(ii) For purposes of clause (i), an S corporation and its shareholders shall be treated in the same manner as a partnership and its partners.
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(1) The term “return” means any return of any tax imposed by this title, any administrative adjustment request under section 6227, and any partnership adjustment tracking report under section 6226(b)(4)(A).
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(a) In addition to the penalty imposed by section 7203 (relating to willful failure to file return, supply information, or pay tax), if any partnership required to file a return under section 6031, or a partnership adjustment tracking report under section 6226(b)(4)(A), for any taxable year—(1) fails to file such return, or such report, at the time prescribed therefor (determined with regard to any extension of time for filing), or(2) files a return or a report which fails to show the information required under section 6031 or 6226(b)(4)(A), respectively,such partnership shall be liable for a penalty determined under subsection (b) for each month (or fraction thereof) during which such failure continues (but not to exceed 12 months), unless it is shown that such failure is due to reasonable cause.
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(2) files a return or a report which fails to show the information required under section 6031 or 6226(b)(4)(A), respectively,
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(f) An administrative adjustment request under section 6227 and a partnership adjustment tracking report under section 6226(b)(4)(A) shall be treated as a return for purposes of this section.
Citations to §6226(b)(4)(A)(ii)
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(i) failure to comply with the requirements of section 6226(b)(4)(A)(ii),
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(i) For purposes of this section, any failure to comply with section 6226(b)(4)(A)(ii) shall be treated as a failure to pay the amount described in subclause (II) thereof and such amount shall be treated for purposes of this section as an amount shown as tax on a return specified in subsection (a)(1).
Citations to §6226(b)(4)(A)(ii)(II)
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(A) the amount described in subclause (II) of section 6226(b)(4)(A)(ii) (including any failure to satisfy the requirement of subclause (I) of such section which is treated as a failure to pay such amount under section 6651(i)), and
Citations to §6226(c)
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(1) 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).