§6227. Administrative adjustment request by partnership — Inbound Citations
26 U.S.C. § 6227
Cited by 7 provisions in release 119-102.
Citations to 26 U.S.C. § 6227 as a whole
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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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(B) in the case of an administrative adjustment request under section 6227, such administrative adjustment request is made, or
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(C) the date on which the partnership filed an administrative adjustment request with respect to such year under section 6227, or
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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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(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.
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(B) establish and maintain a toll-free telephone number for taxpayers to use to confidentially register complaints of misconduct by Internal Revenue Service employees and incorporate the telephone number in the statement required by section 6227 of the Omnibus Taxpayer Bill of Rights (Internal Revenue Service Publication No. 1); and
Citations to §6227(b)(1)
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(2) in the case of an administrative adjustment request to which section 6227(b)(1) applies, the underpayment shall be paid and may be assessed when the request is filed.