--- kind: "section" citation: "26 U.S.C. § 6231" title: "26" title_heading: "Internal Revenue Code" number: "6231" heading: "Notice of proceedings and adjustment" release: "119-102" date: "2026-07-12" url: "https://uscodex.org/usc/26/6231" units: - "Subtitle F — Procedure and Administration" - "Chapter 63 — Assessment" - "Subchapter C — Treatment of Partnerships" - "Part III — Procedure" --- # §6231. Notice of proceedings and adjustment - (a) **In general—** The [Secretary](/usc/26/7701.md?p=a-11-B) shall mail to the [partnership](/usc/26/7701.md?p=a-2) and the [partnership](/usc/26/7701.md?p=a-2) representative— - (1) notice of any administrative proceeding initiated at the [partnership](/usc/26/7701.md?p=a-2) level with respect to an adjustment of any [partnership](/usc/26/7701.md?p=a-2)-[related](/usc/26/7701.md?p=a-51-I-vi) item for any [partnership](/usc/26/7701.md?p=a-2) [taxable year](/usc/26/7701.md?p=a-23), or any [partner](/usc/26/7701.md?p=a-2)’s distributive share thereof, - (2) notice of any proposed [partnership](/usc/26/7701.md?p=a-2) adjustment resulting from such proceeding, and - (3) notice of any final [partnership](/usc/26/7701.md?p=a-2) adjustment resulting from such proceeding. Any notice of a final [partnership](/usc/26/7701.md?p=a-2) adjustment shall be sufficient if mailed to the last known address of the [partnership](/usc/26/7701.md?p=a-2) representative or the [partnership](/usc/26/7701.md?p=a-2) (even if the [partnership](/usc/26/7701.md?p=a-2) has terminated its existence). The first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a [partnership](/usc/26/7701.md?p=a-2) under section 6227. - (b) **Timing of notices—** - (1) **Notice of proposed partnership adjustment—** Any notice of a proposed [partnership](/usc/26/7701.md?p=a-2) adjustment shall not be mailed later than the date determined under [section 6235](/usc/26/6235.md) (determined without regard to paragraphs [(2)](#a-2) and [(3)](#a-3) of subsection (a) thereof). - (2) **Notice of final partnership adjustment—** - (A) **In general—** Except to the extent that the [partnership](/usc/26/7701.md?p=a-2) elects to waive the application of this subparagraph, any notice of a final [partnership](/usc/26/7701.md?p=a-2) adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed [partnership](/usc/26/7701.md?p=a-2) adjustment is mailed. - (B) **Statute of limitations on adjustment—** For the period of limitations on making adjustments, see section 6235. - (c) **Further notices restricted—** If the [Secretary](/usc/26/7701.md?p=a-11-B) mails a notice of a final [partnership](/usc/26/7701.md?p=a-2) adjustment to any [partnership](/usc/26/7701.md?p=a-2) for any [partnership](/usc/26/7701.md?p=a-2) [taxable year](/usc/26/7701.md?p=a-23) and the [partnership](/usc/26/7701.md?p=a-2) files a petition under [section 6234](/usc/26/6234.md) with respect to such notice, in the absence of a showing of fraud, malfeasance, or misrepresentation of a material fact, the [Secretary](/usc/26/7701.md?p=a-11-B) shall not mail another such notice to such [partnership](/usc/26/7701.md?p=a-2) with respect to such [taxable year](/usc/26/7701.md?p=a-23). - (d) **Authority to rescind notice with partnership consent—** The [Secretary](/usc/26/7701.md?p=a-11-B) may, with the consent of the [partnership](/usc/26/7701.md?p=a-2), rescind any notice of a [partnership](/usc/26/7701.md?p=a-2) adjustment mailed to such [partnership](/usc/26/7701.md?p=a-2). Any notice so rescinded shall not be treated as a notice of a [partnership](/usc/26/7701.md?p=a-2) adjustment for purposes of this subchapter, and the [taxpayer](/usc/26/7701.md?p=a-14) shall have no right to bring a proceeding under [section 6234](/usc/26/6234.md) with respect to such notice. ## Source credit (Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 632; amended Pub. L. 115–141, div. U, title II, §§ 201(c)(6), 206(h), Mar. 23, 2018, 132 Stat. 1173, 1179.) ## Notes ### Editorial Notes ### Prior Provisions A prior section 6231, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 663; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(B)–(D), (I), July 18, 1984, 98 Stat. 964, 965; Pub. L. 105–34, title XI, § 1141(b), title XII, §§ 1232(a), 1234(a), Aug. 5, 1997, 111 Stat. 981, 1023, 1024; Pub. L. 105–206, title III, § 3507(a), July 22, 1998, 112 Stat. 772; Pub. L. 107–147, title IV, §§ 416(d)(1)(C), 417(19)(C), Mar. 9, 2002, 116 Stat. 55, 57, defined terms for purposes of this subchapter and listed special rules for partnership items, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625. ### Amendments 2018—Subsec. (a). Pub. L. 115–141, § 206(h)(2), substituted “Any notice of a final partnership adjustment” for “Any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed. Such notices” in concluding provisions. Subsec. (a)(1). Pub. L. 115–141, § 201(c)(6), substituted “any partnership-related item for any partnership taxable year” for “any item of income, gain, loss, deduction, or credit of a partnership for a partnership taxable year”. Subsecs. (b) to (d). Pub. L. 115–141, § 206(h)(1), added subsec. (b) and redesignated former subsecs. (b) and (c) as (c) and (d), respectively. ### Statutory Notes and Related Subsidiaries ### Effective Date of 2018 Amendment Amendment by Pub. L. 115–141 effective as if included in section 1101 of Pub. L. 114–74, see section 207 of Pub. L. 115–141, 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 Pub. L. 114–74, set out as a note under section 6221 of this title. ### Special Rule for Certain International Satellite Partnerships Pub. L. 97–248, title IV, § 406, Sept. 3, 1982, 96 Stat. 670, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “[Former] Subchapter C of chapter 63 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] (relating to tax treatment of partnership items), section 6031 of such Code (relating to returns of partnership income), and section 6046A of such Code (relating to returns as to interest in foreign partnerships) shall not apply to the International Telecommunications Satellite Organization, the International Maritime Satellite Organization, and any organization which is a successor of either of such organizations.”