Legal corpus: the complete U.S. Code (59,740 sections, all 53 titles)

Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code
now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 ->
59,740; repo total 105,704 records. Deterministic (byte-identical rerun,
verified on Title 42's 8,356 sections); make check green. make
legal-us-code default now covers every title.

Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>

legal/us/code/title-26/chapter-63/section-6201.md

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+---
+type: "LegalText"
+title: "26 U.S.C. § 6201"
+description: "Assessment authority"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6201"
+citation: "26 U.S.C. § 6201"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6201"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "9d4c0e6a71b778bf8b0e243077c7ba308df51766e5aa2397ae02bc37c5675f25"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "5c26fb36b90909edc732a6d31666324875c873fb94e3dbc02d9b332df39984fe"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6201 - Assessment authority
+
+## Text
+
+(a) Authority of Secretary The Secretary is authorized and required to make the inquiries, determinations, and assessments of all taxes (including interest, additional amounts, additions to the tax, and assessable penalties) imposed by this title, or accruing under any former internal revenue law, which have not been duly paid by stamp at the time and in the manner provided by law. Such authority shall extend to and include the following:
+
+(1) Taxes shown on return The Secretary shall assess all taxes determined by the taxpayer or by the Secretary as to which returns or lists (or payments under section 6225(c)(2)(B)(i)) are made under this title.
+
+(2) Unpaid taxes payable by stamp (A) Omitted stamps Whenever any article upon which a tax is required to be paid by means of a stamp is sold or removed for sale or use by the manufacturer thereof or whenever any transaction or act upon which a tax is required to be paid by means of a stamp occurs without the use of the proper stamp, it shall be the duty of the Secretary, upon such information as he can obtain, to estimate the amount of tax which has been omitted to be paid and to make assessment therefor upon the person or persons the Secretary determines to be liable for such tax.
+
+(B) Check or money order not duly paid In any case in which a check or money order received under authority of section 6311 as payment for stamps is not duly paid, the unpaid amount may be immediately assessed as if it were a tax imposed by this title, due at the time of such receipt, from the person who tendered such check or money order.
+
+(3) Erroneous income tax prepayment credits If on any return or claim for refund of income taxes under subtitle A there is an overstatement of the credit for income tax withheld at the source, or of the amount paid as estimated income tax, the amount so overstated which is allowed against the tax shown on the return or which is allowed as a credit or refund may be assessed by the Secretary in the same manner as in the case of a mathematical or clerical error appearing upon the return, except that the provisions of section 6213(b)(2) (relating to abatement of mathematical or clerical error assessments) shall not apply with regard to any assessment under this paragraph.
+
+(4) Certain orders of criminal restitution (A) In general The Secretary shall assess and collect the amount of restitution under an order pursuant to section 3556 of title 18, United States Code, for failure to pay any tax imposed under this title in the same manner as if such amount were such tax.
+
+(B) Time of assessment An assessment of an amount of restitution under an order described in subparagraph (A) shall not be made before all appeals of such order are concluded and the right to make all such appeals has expired.
+
+(C) Restriction on challenge of assessment The amount of such restitution may not be challenged by the person against whom assessed on the basis of the existence or amount of the underlying tax liability in any proceeding authorized under this title (including in any suit or proceeding in court permitted under section 7422).
+
+(b) Amount not to be assessed (1) Estimated income tax No unpaid amount of estimated income tax required to be paid under section 6654 or 6655 shall be assessed.
+
+(2) Federal unemployment tax No unpaid amount of Federal unemployment tax for any calendar quarter or other period of a calendar year, computed as provided in section 6157, shall be assessed.
+
+(c) Compensation of child Any income tax under chapter 1 assessed against a child, to the extent attributable to amounts includible in the gross income of the child, and not of the parent, solely by reason of section 73(a), shall, if not paid by the child, for all purposes be considered as having also been properly assessed against the parent.
+
+(d) Required reasonable verification of information returns In any court proceeding, if a taxpayer asserts a reasonable dispute with respect to any item of income reported on an information return filed with the Secretary under subpart B or C of part III of subchapter A of chapter 61 by a third party and the taxpayer has fully cooperated with the Secretary (including providing, within a reasonable period of time, access to and inspection of all witnesses, information, and documents within the control of the taxpayer as reasonably requested by the Secretary), the Secretary shall have the burden of producing reasonable and probative information concerning such deficiency in addition to such information return.
+
+(e) Deficiency proceedings For special rules applicable to deficiencies of income, estate, gift, and certain excise taxes, see subchapter B.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 767; Pub. L. 89–44, title VIII, § 809(d)(4)(A), June 21, 1965, 79 Stat. 168; Pub. L. 91–53, § 2(b), Aug. 7, 1969, 83 Stat. 92; Pub. L. 91–172, title I, § 101(j)(38), Dec. 30, 1969, 83 Stat. 530; Pub. L. 91–258, title II, § 207(d)(1), (2), May 21, 1970, 84 Stat. 248; Pub. L. 93–406, title II, § 1016(a)(8), Sept. 2, 1974, 88 Stat. 929; Pub. L. 94–12, title II, § 204(b)(2), Mar. 29, 1975, 89 Stat. 31; Pub. L. 94–455, title XII, § 1206(c)(2), title XIII, § 1307(d)(2)(D), title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1704, 1727, 1834; Pub. L. 97–424, title V, § 515(b)(6)(E), Jan. 6, 1983, 96 Stat. 2182; Pub. L. 98–76, title II, § 231(b)(2)(A), Aug. 12, 1983, 97 Stat. 429; Pub. L. 98–369, div. A, title IV, §§ 412(b)(5), 474(r)(32), July 18, 1984, 98 Stat. 792, 845; Pub. L. 100–203, title X, § 10301(b)(3), Dec. 22, 1987, 101 Stat. 1330–429; Pub. L. 100–647, title I, § 1015(r)(1), title VII, § 7106(c)(2), Nov. 10, 1988, 102 Stat. 3572, 3773; Pub. L. 104–168, title VI, § 602(a), July 30, 1996, 110 Stat. 1463; Pub. L. 111–237, § 3(a), Aug. 16, 2010, 124 Stat. 2497; Pub. L. 115–141, div. U, title II, § 203(b), Mar. 23, 2018, 132 Stat. 1176.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2018—Subsec. (a)(1). Pub. L. 115–141 inserted “(or payments under section 6225(c)(2)(B)(i))” after “returns or lists”. 2010—Subsec. (a)(4). Pub. L. 111–237 added par. (4). 1996—Subsecs. (d), (e). Pub. L. 104–168 added subsec. (d) and redesignated former subsec. (d) as (e). 1988—Subsec. (a)(4). Pub. L. 100–647, § 1015(r)(1), struck out par. (4) which read as follows: “If on any return or claim for refund of income taxes under subtitle A there is an overstatement of the credit allowable by section 34 (relating to certain uses of gasoline and special fuels) or section 32 (relating to earned income), the amount so overstated which is allowed against the tax shown on the return or which is allowed as a credit or refund may be assessed by the Secretary in the same manner as in the case of a mathematical or clerical error appearing upon the return, except that the provisions of section 6213(b)(2) (relating to abatement of mathematical or clerical error assessments) shall not apply with regard to any assessment under this paragraph.” Subsec. (b)(2). Pub. L. 100–647, § 7106(c)(2), struck out “or tax imposed by section 3321” after “employment tax”. 1987—Subsec. (b)(1). Pub. L. 100–203 substituted “section 6654 or 6655” for “section 6154 or 6654”. 1984—Subsec. (a)(4). Pub. L. 98–369, § 474(r)(32), substituted “section 32 or 34” for “section 39 or 43” in heading, and in text substituted “section 34” for “section 39” and “section 32” for “section 43”. Subsec. (b)(1). Pub. L. 98–369, § 412(b)(5), amended par. (1) generally, substituting “estimated income tax required to be paid under section 6154 or 6654” for “estimated tax under section 6153 or 6154”. 1983—Subsec. (a)(4). Pub. L. 97–424 substituted “and special fuels” for “, special fuels, and lubricating oil” after “gasoline”. Subsec. (b)(2). Pub. L. 98–76 substituted “Federal unemployment tax or tax imposed by section 3321” for “Federal unemployment tax”. 1976—Subsec. (a). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. Subsec. (a)(3), (4). Pub. L. 94–455, §§ 1206(c)(2), 1906(b)(13)(A), struck out “or his delegate” after “Secretary”, substituted “mathematical or clerical error” for “mathematical error” after “the case of”, and inserted “, except that the provisions of section 6213(b)(2) (relating to abatement of mathematical or clerical error assessments) shall not apply with regard to any assessment under this paragraph” after “upon the return”. Subsec. (d). Pub. L. 94–455, § 1307(d)(2)(D), substituted “and certain excise taxes” for “chapter 42, and chapter 43 taxes” after “estate, gift”. 1975—Subsec. (a)(4). Pub. L. 94–12 inserted reference to section 43 in heading and substituted “oil) or section 43 (relating to earned income),” for “oil),” in text. 1974—Subsec. (d). Pub. L. 93–406 inserted reference to chapter 43 taxes. 1970—Subsec. (a)(4). Pub. L. 91–258 inserted provision for overstatement of credit allowable by section 39 (relating to certain uses of special fuels) in text and substituted “under section 39” for “for use of gasoline” in heading. 1969—Subsec. (b). Pub. L. 91–53 added subsec. (b) heading and par. (2), and redesignated former subsec. (b), including its heading, as par. (1). Subsec. (d). Pub. L. 91–172 inserted reference to chapter 42 taxes. 1965—Subsec. (a)(4). Pub. L. 89–44 added par. (4).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 of 2010 AmendmentPub. L. 111–237, § 3(c), Aug. 16, 2010, 124 Stat. 2498, provided that: “The amendments made by this section [amending this section and sections 6213 and 6501 of this title] shall apply to restitution ordered after the date of the enactment of this Act [Aug. 16, 2010].”
+
+Effective Date of 1996 AmendmentPub. L. 104–168, title VI, § 602(b), July 30, 1996, 110 Stat. 1463, provided that: “The amendment made by subsection (a) [amending this section] shall take effect on the date of the enactment of this Act [July 30, 1996].”
+
+Effective Date of 1988 AmendmentPub. L. 100–647, title I, § 1015(r)(4), Nov. 10, 1988, 102 Stat. 3573, provided that: “The amendments made by this subsection [amending this section and sections 6211 and 6213 of this title] shall apply to notices of deficiencies mailed after the date of the enactment of this Act [Nov. 10, 1988].” Amendment by section 7106(c)(2) of Pub. L. 100–647 applicable to remuneration paid after Dec. 31, 1988, see section 7106(d) of Pub. L. 100–647, set out as a note under section 3321 of this title.
+
+Effective Date of 1987 AmendmentAmendment by Pub. L. 100–203 applicable to taxable years beginning after Dec. 31, 1987, see section 10301(c) of Pub. L. 100–203, set out as a note under section 585 of this title.
+
+Effective Date of 1984 AmendmentAmendment by section 412(b)(5) of Pub. L. 98–369 applicable with respect to taxable years beginning after Dec. 31, 1984, see section 414(a)(1) of Pub. L. 98–369, set out as a note under section 6654 of this title. Amendment by section 474(r)(32) of Pub. L. 98–369 applicable to taxable years beginning after Dec. 31, 1983, and to carrybacks from such years, see section 475(a) of Pub. L. 98–369, set out as a note under section 21 of this title.
+
+Effective Date of 1983 AmendmentAmendment by Pub. L. 98–76 applicable to remuneration paid after June 30, 1986, see section 231(d) of Pub. L. 98–76, set out as an Effective Date note under section 3321 of this title. Amendment by Pub. L. 97–424 applicable with respect to articles sold after Jan. 6, 1983, see section 515(c) of Pub. L. 97–424, set out as a note under section 34 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1206(c)(2) of Pub. L. 94–455 applicable with respect to returns filed after Dec. 31, 1976, see section 1206(d) of Pub. L. 94–455, set out as a note under section 6213 of this title. Amendment by section 1307(d)(2)(D) of Pub. L. 94–455 effective on and after Oct. 4, 1976, see section 1307(e) of Pub. L. 94–455, set out as a note under section 501 of this title.
+
+Effective Date of 1975 AmendmentAmendment by Pub. L. 94–12 applicable to taxable years beginning after Dec. 31, 1974, see section 209(b) of Pub. L. 94–12, as amended, set out as a note under section 32 of this title.
+
+Effective Date of 1974 AmendmentAmendment by Pub. L. 93–406 applicable, except as otherwise provided in section 1017(c) through (i) of Pub. L. 93–406, for plan years beginning after Sept. 2, 1974, but, in the case of plans in existence on Jan. 1, 1974, amendment by Pub. L. 93–406 applicable for plan years beginning after Dec. 31, 1975, see section 1017 of Pub. L. 93–406, set out as an Effective Date; Transitional Rules note under section 410 of this title.
+
+Effective Date of 1970 AmendmentAmendment by Pub. L. 91–258 effective July 1, 1970, see section 211(a) of Pub. L. 91–258, set out as a note under section 4041 of this title.
+
+Effective Date of 1969 AmendmentsAmendment by Pub. L. 91–172 effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as an Effective Date note under section 4940 of this title. Amendment by Pub. L. 91–53 applicable with respect to calendar years beginning after Dec. 31, 1969, see section 4(a) of Pub. L. 91–53, set out as an Effective Date note under section 6157 of this title.
+
+Effective Date of 1965 AmendmentAmendment by Pub. L. 89–44 applicable to taxable years beginning on or after July 1, 1965, see section 809(f) of Pub. L. 89–44, set out as a note under section 6420 of this title.

legal/us/code/title-26/chapter-63/section-6202.md

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+---
+type: "LegalText"
+title: "26 U.S.C. § 6202"
+description: "Establishment by regulations of mode or time of assessment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6202"
+citation: "26 U.S.C. § 6202"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6202"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "f352afd4c60302db0a3261058af013711be5fb97db6cf9baa330b3762d90825e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e0e4815471eae650416f62b41dc08ccbd1f8da67ce4949d8fc7ce660e42574a3"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6202 - Establishment by regulations of mode or time of assessment
+
+## Text
+
+If the mode or time for the assessment of any internal revenue tax (including interest, additional amounts, additions to the tax, and assessable penalties) is not otherwise provided for, the Secretary may establish the same by regulations.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 768; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

legal/us/code/title-26/chapter-63/section-6203.md

@@ -0,0 +1,41 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6203"
+description: "Method of assessment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6203"
+citation: "26 U.S.C. § 6203"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6203"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "280ed36a0a0b9bb3b58e16c763fd3473a73a1ac3cba5774b3f244db842e1fedf"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "827aa6a11f5c6e90b96e1825359abfc6a652857336785098d6d79c93c5b6ebdf"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6203 - Method of assessment
+
+## Text
+
+The assessment shall be made by recording the liability of the taxpayer in the office of the Secretary in accordance with rules or regulations prescribed by the Secretary. Upon request of the taxpayer, the Secretary shall furnish the taxpayer a copy of the record of the assessment.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 768; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.

legal/us/code/title-26/chapter-63/section-6204.md

@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6204"
+description: "Supplemental assessments"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6204"
+citation: "26 U.S.C. § 6204"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6204"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "16a0cdfb74b46112792fb81403b4413422914931cb8e94c970e389c9bf04a38e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "deeb9faf252a87b3ea3a4cc0140f92ba80a17cab0c5af34dec49f126c76fdbea"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6204 - Supplemental assessments
+
+## Text
+
+(a) General rule The Secretary may, at any time within the period prescribed for assessment, make a supplemental assessment whenever it is ascertained that any assessment is imperfect or incomplete in any material respect.
+
+(b) Restrictions on assessment For restrictions on assessment of deficiencies in income, estate, gift, and certain excise taxes, see section 6213.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 768; Pub. L. 93–406, title II, § 1016(a)(27), Sept. 2, 1974, 88 Stat. 932; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Subsec. (a). Pub. L. 94–455 struck out “or his delegate” after “Secretary”. 1974—Subsec. (b). Pub. L. 93–406 substituted “gift, and certain excise taxes” for “and gift taxes”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1974 AmendmentAmendment by Pub. L. 93–406 applicable, except as otherwise provided in section 1017(c) through (i) of Pub. L. 93–406, for plan years beginning after Sept. 2, 1974, and, in the case of plans in existence on Jan. 1, 1974, amendment by Pub. L. 93–406 applicable for plan years beginning after Dec. 31, 1975, see section 1017 of Pub. L. 93–406, set out as an Effective Date; Transitional Rules note under section 410 of this title.

legal/us/code/title-26/chapter-63/section-6205.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6205"
+description: "Special rules applicable to certain employment taxes"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6205"
+citation: "26 U.S.C. § 6205"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6205"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "5fb7a3f9615c8ddf1b54bd59cd7b99bd2b032511e3a9066844ad25ab2e5a2e09"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "8d967213b188f3b08041cf9bdff7ac576f33a27707be8582ceb0a88435a76ae8"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6205 - Special rules applicable to certain employment taxes
+
+## Text
+
+(a) Adjustment of tax (1) General rule If less than the correct amount of tax imposed by section 3101, 3111, 3201, 3221, or 3402 is paid with respect to any payment of wages or compensation, proper adjustments, with respect to both the tax and the amount to be deducted, shall be made, without interest, in such manner and at such times as the Secretary may by regulations prescribe.
+
+(2) United States as employer For purposes of this subsection, in the case of remuneration received from the United States or a wholly-owned instrumentality thereof during any calendar year, each head of a Federal agency or instrumentality who makes a return pursuant to section 3122 and each agent, designated by the head of a Federal agency or instrumentality, who makes a return pursuant to such section shall be deemed a separate employer.
+
+(3) Guam or American Samoa as employer For purposes of this subsection, in the case of remuneration received during any calendar year from the Government of Guam, the Government of American Samoa, a political subdivision of either, or any instrumentality of any one or more of the foregoing which is wholly owned thereby, the Governor of Guam, the Governor of American Samoa, and each agent designated by either who makes a return pursuant to section 3125 shall be deemed a separate employer.
+
+(4) District of Columbia as employer For purposes of this subsection, in the case of remuneration received during any calendar year from the District of Columbia or any instrumentality which is wholly owned thereby, the Mayor of the District of Columbia and each agent designated by him who makes a return pursuant to section 3125 shall be deemed a separate employer.
+
+(5) States and political subdivisions as employer For purposes of this subsection, in the case of remuneration received from a State or any political subdivision thereof (or any instrumentality of any one or more of the foregoing which is wholly owned thereby) during any calendar year, each head of an agency or instrumentality, and each agent designated by either, who makes a return pursuant to section 3125 shall be deemed a separate employer.
+
+(b) Underpayments If less than the correct amount of tax imposed by section 3101, 3111, 3201, 3221, or 3402 is paid or deducted with respect to any payment of wages or compensation and the underpayment cannot be adjusted under subsection (a) of this section, the amount of the underpayment shall be assessed and collected in such manner and at such times (subject to the statute of limitations properly applicable thereto) as the Secretary may by regulations prescribe.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 768; Pub. L. 86–778, title I, § 103(r)(1), Sept. 13, 1960, 74 Stat. 940; Pub. L. 89–97, title III, § 317(d), July 30, 1965, 79 Stat. 389; Pub. L. 94–455, title XIX, § 1906(a)(13), (b)(13)(A), Oct. 4, 1976, 90 Stat. 1825, 1834; Pub. L. 99–272, title XIII, § 13205(a)(2)(D), Apr. 7, 1986, 100 Stat. 315.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1986—Subsec. (a)(5). Pub. L. 99–272 added par. (5). 1976—Subsec. (a)(1). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. Subsec. (a)(4). Pub. L. 94–455, § 1906(a)(13), substituted “Mayor of the District of Columbia and each agent designated by him” for “Commissioners of the District of Columbia and each agent designated by them” after “owned thereby, the”. Subsec. (b). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. 1965—Subsec. (a)(4). Pub. L. 89–97 added par. (4). 1960—Subsec. (a)(3). Pub. L. 86–778 added par. (3).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1986 AmendmentAmendment by Pub. L. 99–272 applicable to services performed after Mar. 31, 1986, see section 13205(d)(1) of Pub. L. 99–272, set out as a note under section 3121 of this title.
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 effective on first day of first month which begins more than 90 days after Oct. 4, 1976, see section 1906(d)(1) of Pub. L. 94–455, set out as a note under section 6013 of this title.
+
+Effective Date of 1965 AmendmentAmendment by Pub. L. 89–97 applicable with respect to services performed after quarter ending Sept. 30, 1965, and after quarter in which Secretary of the Treasury receives a certification from Commissioners of District of Columbia expressing their desire to have insurance system established by sections 401 et seq. and 1395c et seq. of Title 42, The Public Health and Welfare, extended to officers and employees coming under provisions of such amendments, see section 317(g) of Pub. L. 89–97, set out as a note under section 410 of Title 42.
+
+Effective Date of 1960 AmendmentAmendment by Pub. L. 86–778 applicable only with respect to (1) service in the employ of the Government of Guam or any political subdivision thereof, or any instrumentality of any one or more of the foregoing wholly owned thereby, which is performed after 1960 and after the calendar quarter in which the Secretary of the Treasury receives a certification by the Governor of Guam that legislation has been enacted by the Government of Guam expressing its desire to have the insurance system established by title II of the Social Security Act, section 401 et seq. of Title 42, The Public Health and Welfare, extended to the officers and employees of such Government and such political subdivisions and instrumentalities, and (2) service in the employ of the Government of American Samoa or any political subdivision thereof or any instrumentality of any one or more of the foregoing wholly owned thereby, which is performed after 1960 and after the calendar quarter in which the Secretary of the Treasury receives a certification by the Governor of American Samoa that the Government of American Samoa desires to have the insurance system established by title II of the Social Security Act, section 401 et seq. of Title 42, extended to the officers and employees of such Government and such political subdivisions and instrumentalities, see section 103(v)(1) of Pub. L. 86–778, set out as a note under section 402 of Title 42.

legal/us/code/title-26/chapter-63/section-6206.md

@@ -0,0 +1,63 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6206"
+description: "Special rules applicable to excessive claims under certain sections"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6206"
+citation: "26 U.S.C. § 6206"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6206"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "cd325ccae164e4f67ad5534cd2bde49b3890bb0e26b48bd5baf4a76350f7a15e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "185a5990071d877616331e2495f2c347381483425d7038c26e67b352b8874e5d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6206 - Special rules applicable to excessive claims under certain sections
+
+## Text
+
+Any portion of a refund made under section 6416(a)(4) and any portion of a payment made under section 6420, 6421, 6427, or 6435 which constitutes an excessive amount (as defined in section 6675(b)), and any civil penalty provided by section 6675, may be assessed and collected as if it were a tax imposed by section 4081 (with respect to refunds under section 6416(a)(4) and payments under sections 6420, 6421, and 6435), or 4041 or 4081 (with respect to payments under section 6427) and as if the person who made the claim were liable for such tax. The period for assessing any such portion, and for assessing any such penalty, shall be 3 years from the last day prescribed for the filing of the claim under section 6416(a)(4), 6420, 6421, 6427, or 6435, as the case may be.
+
+(Added Apr. 2, 1956, ch. 160, § 4(b)(1), 70 Stat. 90; amended June 29, 1956, ch. 462, title II, § 208(d)(1), 70 Stat. 396; Pub. L. 89–44, title II, § 202(c)(2)(A), June 21, 1965, 79 Stat. 139; Pub. L. 91–258, title II, § 207(d)(3), May 21, 1970, 84 Stat. 248; Pub. L. 97–424, title V, § 515(b)(3)(A), Jan. 6, 1983, 96 Stat. 2181; Pub. L. 100–203, title X, § 10502(d)(5), Dec. 22, 1987, 101 Stat. 1330–444; Pub. L. 103–66, title XIII, § 13242(d)(14), Aug. 10, 1993, 107 Stat. 524; Pub. L. 108–357, title VIII, § 853(d)(2)(F), Oct. 22, 2004, 118 Stat. 1613; Pub. L. 109–59, title XI, § 11163(d)(1), Aug. 10, 2005, 119 Stat. 1974; Pub. L. 119–21, title VII, § 70525(b)(1), July 4, 2025, 139 Stat. 282.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6206 was renumbered 6207 of this title.
+
+Amendments2025—Pub. L. 119–21 substituted “6427, or 6435” for “or 6427” in two places and “6420, 6421, and 6435” for “6420 and 6421”. 2005—Pub. L. 109–59 substituted “certain sections” for “sections 6420, 6421, and 6427” in section catchline, in first sentence substituted “Any portion of a refund made under section 6416(a)(4) and any portion” for “Any portion” and “refunds under section 6416(a)(4) and payments under sections 6420” for “payments under sections 6420”, and in second sentence substituted “section 6416(a)(4), 6420” for “section 6420”. 2004—Pub. L. 108–357 substituted “or 4081” for “, 4081, or 4091”. 1993—Pub. L. 103–66 substituted “4041, 4081, or 4091” for “4041 or 4091”. 1987—Pub. L. 100–203 substituted “or 4041 or 4091” for “or 4041”. 1983—Pub. L. 97–424 struck out reference to section 6424 in section catchline, and in text struck out “4091 (with respect to payments under section 6424),” after “6421),”, and “6424,” wherever appearing. 1970—Pub. L. 91–258 inserted reference to section 6427 in section catchline, inserted reference to section 6427 in first and second sentences, and substituted “by section 4081 (with respect to payments under sections 6420 and 6421), 4091 (with respect to payments under section 6424), or 4041 (with respect to payments under section 6427)” for “by section 4081 (or, in the case of lubricating oil, by section 4091)”, in first sentence, respectively. 1965—Pub. L. 89–44 struck out “6420 and 6421” wherever appearing in section catchline and text and substituted therefor “6420, 6421, and 6424” and inserted “(or, in the case of lubricating oil, by section 4091)” after “4081” in text. 1956—Act June 29, 1956, inserted reference to excessive claims under section 6421 in section catchline and text.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2025 AmendmentPub. L. 119–21, title VII, § 70525(c), July 4, 2025, 139 Stat. 283, provided that: “The amendments made by this section [enacting section 6435 of this title and amending this section and sections 6430 and 6675 of this title] shall apply to eligible indelibly dyed diesel fuel or kerosene removed on or after the date that is 180 days after the date of the enactment of this section [July 4, 2025].”
+
+Effective Date of 2005 AmendmentAmendment by Pub. L. 109–59 applicable to sales after Dec. 31, 2005, see section 11163(e) of Pub. L. 109–59, set out as a note under section 4101 of this title.
+
+Effective Date of 2004 AmendmentAmendment by Pub. L. 108–357 applicable to aviation-grade kerosene removed, entered, or sold after Dec. 31, 2004, see section 853(e) of Pub. L. 108–357, set out as a note under section 4041 of this title.
+
+Effective Date of 1993 AmendmentAmendment by Pub. L. 103–66 effective Jan. 1, 1994, see section 13242(e) of Pub. L. 103–66, set out as a note under section 4041 of this title.
+
+Effective Date of 1987 AmendmentAmendment by Pub. L. 100–203 applicable to sales after Mar. 31, 1988, see section 10502(e) of Pub. L. 100–203, set out as a note under section 40 of this title.
+
+Effective Date of 1983 AmendmentAmendment by Pub. L. 97–424 applicable with respect to articles sold after Jan. 6, 1983, see section 515(c) of Pub. L. 97–424, set out as a note under section 34 of this title.
+
+Effective Date of 1970 AmendmentAmendment by Pub. L. 91–258 effective July 1, 1970, see section 211(a) of Pub. L. 91–258, set out as a note under section 4041 of this title.
+
+Effective Date of 1965 AmendmentAmendment by Pub. L. 89–44 effective Jan. 1, 1966, see section 701(a)(1), (2) of Pub. L. 89–44, set out as a note under section 4161 of this title.
+
+Effective Date of 1956 AmendmentAmendment by act June 29, 1956, effective June 29, 1956, see section 211 of act June 29, 1956, set out as a note under section 4041 of this title.

legal/us/code/title-26/chapter-63/section-6207.md

@@ -0,0 +1,55 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6207"
+description: "Cross references"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6207"
+citation: "26 U.S.C. § 6207"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6207"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "519aac3641b4b0898009323f97568ebcf82d36c3bec74566ac4dd370512b779b"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "9e24c0caeb35b83579be9c3922085f092d9a4325c22f08b8ae6d9ce33636a03b"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6207 - Cross references
+
+## Text
+
+(1) For prohibition of suits to restrain assessment of any tax, see section 7421.
+
+(2) For prohibition of assessment of taxes against insolvent banks, see section 7507.
+
+(3) For assessment where property subject to tax has been sold in a distraint proceeding without the tax having been assessed prior to such sale, see section 6342.
+
+(4) For assessment with respect to taxes required to be paid by chapter 52, see section 5703.
+
+(5) For assessment in case of distilled spirits removed from place where distilled and not deposited in bonded warehouse, see section 5006(c).
+
+(6) For period of limitation upon assessment, see chapter 66.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 769, § 6206; renumbered § 6207, Apr. 2, 1956, ch. 160, § 4(b)(1), 70 Stat. 90; amended Pub. L. 85–859, title II, § 204(2), (3), Sept. 2, 1958, 72 Stat. 1428; Pub. L. 94–455, title XIX, § 1906(a)(14), Oct. 4, 1976, 90 Stat. 1825.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Par. (7). Pub. L. 94–455 struck out par. (7) relating to cross reference for assessment under the provisions of the Tariff Act of 1930. 1958—Par. (4). Pub. L. 85–859, § 204(2), substituted “with respect to taxes required to be paid by chapter 52, see section 5703” for “in case of sale or removal of tobacco, snuff, cigars, and cigarettes without the use of the proper stamps, see section 5703(d)”. Pars. (6) to (9). Pub. L. 85–859, § 204(3), redesignated pars. (8) and (9) as (6) and (7), respectively, and struck out former pars. (6) and (7) which contained cross references relating to assessments in case of certain spirits subject to excessive leakage and to assessment of deficiencies in production of distilled spirits.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1958 AmendmentAmendment by Pub. L. 85–859 effective Sept. 3, 1958, see section 210(a)(1) of Pub. L. 85–859, set out as an Effective Date note under section 5001 of this title.

legal/us/code/title-26/chapter-63/section-6214.md

@@ -0,0 +1,71 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6214"
+description: "Determinations by Tax Court"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6214"
+citation: "26 U.S.C. § 6214"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6214"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "f4cd286f310da65a7a51c8b5f721f259ab8302a64583a939c7ccd1d58dc28f04"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "8665280c512d684be682e107d85ce08c31be95854f27f1b53aa9f832b771bbfd"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6214 - Determinations by Tax Court
+
+## Text
+
+(a) Jurisdiction as to increase of deficiency, additional amounts, or additions to the tax Except as provided by section 7463, the Tax Court shall have jurisdiction to redetermine the correct amount of the deficiency even if the amount so redetermined is greater than the amount of the deficiency, notice of which has been mailed to the taxpayer, and to determine whether any additional amount, or any addition to the tax should be assessed, if claim therefor is asserted by the Secretary at or before the hearing or a rehearing.
+
+(b) Jurisdiction over other years and quarters The Tax Court in redetermining a deficiency of income tax for any taxable year or of gift tax for any calendar year or calendar quarter shall consider such facts with relation to the taxes for other years or calendar quarters as may be necessary correctly to redetermine the amount of such deficiency, but in so doing shall have no jurisdiction to determine whether or not the tax for any other year or calendar quarter has been overpaid or underpaid. Notwithstanding the preceding sentence, the Tax Court may apply the doctrine of equitable recoupment to the same extent that it is available in civil tax cases before the district courts of the United States and the United States Court of Federal Claims.
+
+(c) Taxes imposed by section 507 or chapter 41, 42, 43, or 44 The Tax Court, in redetermining a deficiency of any tax imposed by section 507 or chapter 41, 42, 43, or 44 for any period, act, or failure to act, shall consider such facts with relation to the taxes under chapter 41, 42, 43, or 44 for other periods, acts, or failures to act as may be necessary correctly to redetermine the amount of such deficiency, but in so doing shall have no jurisdiction to determine whether or not the taxes under chapter 41, 42, 43, or 44 for any other period, act, or failure to act have been overpaid or underpaid. The Tax Court, in redetermining a deficiency of any second tier tax (as defined in section 4963(b)), shall make a determination with respect to whether the taxable event has been corrected.
+
+(d) Final decisions of Tax Court For purposes of this chapter, chapter 41, 42, 43, or 44, and subtitles A or B the date on which a decision of the Tax Court becomes final shall be determined according to the provisions of section 7481.
+
+(e) Cross reference For provision giving Tax Court jurisdiction to order a refund of an overpayment and to award sanctions, see section 6512(b)(2).
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 773; Pub. L. 91–172, title I, § 101(j)(43), (44), title IX, § 960(a), Dec. 30, 1969, 83 Stat. 530, 531, 734; Pub. L. 91–614, title I, § 102(d)(6), Dec. 31, 1970, 84 Stat. 1842; Pub. L. 93–406, title II, § 1016(a)(12), Sept. 2, 1974, 88 Stat. 930; Pub. L. 94–455, title XIII, § 1307(d)(2)(F)(iv), (H), title XVI, § 1605(b)(7), title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1728, 1755, 1834; Pub. L. 96–223, title I, § 101(f)(1)(F), (G), Apr. 2, 1980, 94 Stat. 252; Pub. L. 96–596, § 2(b), Dec. 24, 1980, 94 Stat. 3472; Pub. L. 98–369, div. A, title I, § 144(b), July 18, 1984, 98 Stat. 683; Pub. L. 99–514, title XV, §§ 1511(c)(8), 1554(a), title XVIII, § 1833, Oct. 22, 1986, 100 Stat. 2745, 2754, 2852; Pub. L. 100–418, title I, § 1941(b)(2)(B)(vi), (vii), Aug. 23, 1988, 102 Stat. 1323; Pub. L. 100–647, title VI, § 6244(b)(1), Nov. 10, 1988, 102 Stat. 3750; Pub. L. 104–188, title I, § 1704(t)(16), Aug. 20, 1996, 110 Stat. 1888; Pub. L. 109–280, title VIII, § 858(a), Aug. 17, 2006, 120 Stat. 1020.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2006—Subsec. (b). Pub. L. 109–280 inserted at end “Notwithstanding the preceding sentence, the Tax Court may apply the doctrine of equitable recoupment to the same extent that it is available in civil tax cases before the district courts of the United States and the United States Court of Federal Claims.” 1996—Subsec. (e). Pub. L. 104–188 amended subsec. (e) generally, striking par. (2) designation and par. (1) which provided cross reference to section 6621(c)(4) of this title for provision giving Tax Court jurisdiction to determine whether any portion of deficiency is a substantial underpayment attributable to tax motivated transactions. 1988—Subsec. (c). Pub. L. 100–418, § 1941(b)(2)(B)(vi), substituted “or 44” for “44, or 45” in heading and wherever appearing in text. Subsec. (d). Pub. L. 100–418, § 1941(b)(2)(B)(vii), substituted “or 44” for “44, or 45”. Subsec. (e). Pub. L. 100–647 substituted “references” for “reference” in heading, designated existing provisions as par. (1), and added par. (2). 1986—Subsec. (a). Pub. L. 99–514, § 1554(a), substituted “any addition to the tax” for “addition to the tax”. Subsec. (c). Pub. L. 99–514, § 1833, substituted “section 4963(b)” for “section 4962(b)”. Subsec. (e). Pub. L. 99–514, § 1511(c)(8), substituted “section 6621(c)(4)” for “section 6621(d)(4)”. 1984—Subsec. (e). Pub. L. 98–369 added subsec. (e). 1980—Subsec. (c). Pub. L. 96–596 inserted provision directing the Tax Court, in redetermining a deficiency of any second tier tax, to make a determination with respect to whether the taxable event has been corrected. Pub. L. 96–223, § 101(f)(1)(F), inserted reference to chapter 45. Subsec. (d). Pub. L. 96–223, § 101(f)(1)(G), inserted reference to chapter 45. 1976—Subsec. (a). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. Subsec. (c). Pub. L. 94–455, §§ 1307(d)(2)(F)(iv), (H), 1605(b)(7)(A), (B), substituted in heading and in text “41, 42, 43, or 44” for “42 or 43”. Subsec. (d). Pub. L. 94–455, §§ 1307(d)(2)(F)(iv), 1605(b)(7)(C), substituted “41, 42, 43, or 44” for “42 or 43”. 1974—Subsec. (c). Pub. L. 93–406, § 1016(a)(12)(A), (B), inserted reference to chapter 43 in heading and in text. Subsec. (d). Pub. L. 93–406, § 1016(a)(12)(C), inserted reference to chapter 43. 1970—Subsec. (b). Pub. L. 91–614 inserted reference to calendar quarters in heading and in text in regard to gift tax deficiencies. 1969—Subsec. (a). Pub. L. 91–172, § 960(a), inserted reference to exception provided for in section 7463 of this title. Subsecs. (c), (d). Pub. L. 91–172, § 101(j)(43), (44), added subsec. (c), redesignated former subsec. (c) as (d), and, in subsec. (d) as so redesignated, inserted reference to chapter 42.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2006 AmendmentPub. L. 109–280, title VIII, § 858(b), Aug. 17, 2006, 120 Stat. 1020, provided that: “The amendment made by this section [amending this section] shall apply to any action or proceeding in the United States Tax Court with respect to which a decision has not become final (as determined under section 7481 of the Internal Revenue Code of 1986) as of the date of the enactment of this Act [Aug. 17, 2006].”
+
+Effective Date of 1988 AmendmentsPub. L. 100–647, title VI, § 6244(c), Nov. 10, 1988, 102 Stat. 3750, provided that: “The amendments made by this section [amending this section and section 6512 of this title] shall apply to overpayments determined by the Tax Court which have not yet been refunded by the 90th day after the date of the enactment of this Act [Nov. 10, 1988].” Amendment by Pub. L. 100–418 applicable to crude oil removed from the premises on or after Aug. 23, 1988, see section 1941(c) of Pub. L. 100–418, set out as a note under section 164 of this title.
+
+Effective Date of 1986 AmendmentAmendment by section 1511(c)(8) of Pub. L. 99–514 applicable for purposes of determining interest for periods after Dec. 31, 1986, see section 1511(d) of Pub. L. 99–514, set out as a note under section 47 of this title. Pub. L. 99–514, title XV, § 1554(b), Oct. 22, 1986, 100 Stat. 2754, provided that: “The amendment made by subsection (a) [amending this section] shall apply to any action or proceeding in the Tax Court with respect to which a decision has not become final (as determined under section 7481 of the Internal Revenue Code of 1954 [now 1986]) before the date of the enactment of this Act [Oct. 22, 1986].” Amendment by section 1833 of Pub. L. 99–514 effective, except as otherwise provided, as if included in the provisions of the Tax Reform Act of 1984, Pub. L. 98–369, div. A, to which such amendment relates, see section 1881 of Pub. L. 99–514, set out as a note under section 48 of this title.
+
+Effective Date of 1984 AmendmentAmendment by Pub. L. 98–369 applicable with respect to interest accruing after Dec. 31, 1984, see section 144(c) of Pub. L. 98–369, set out as a note under section 6621 of this title.
+
+Effective Date of 1980 AmendmentsFor effective date of amendment by Pub. L. 96–596 with respect to any first tier tax and to any second tier tax, see section 2(d) of Pub. L. 96–596, set out as an Effective Date note under section 4961 of this title. Amendment by Pub. L. 96–223 applicable to periods after Feb. 29, 1980, see section 101(i) of Pub. L. 96–223, set out as a note under section 6161 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1307(d)(2)(F)(iv), (H) of Pub. L. 94–455 effective on and after Oct. 4, 1976, see section 1307(e)(6) of Pub. L. 94–455, set out as a note under section 501 of this title. For effective date of amendment by section 1605(b)(7) of Pub. L. 94–455, see section 1608(d) of Pub. L. 94–455, set out as a note under section 856 of this title.
+
+Effective Date of 1974 AmendmentAmendment by Pub. L. 93–406 applicable, except as otherwise provided in section 1017(c) through (i) of Pub. L. 93–406, for plan years beginning after Sept. 2, 1974, but, in the case of plans in existence on Jan. 1, 1974, amendment by Pub. L. 93–406 applicable for plan years beginning after Dec. 31, 1975, see section 1017 of Pub. L. 93–406, set out as an Effective Date; Transitional Rules note under section 410 of this title.
+
+Effective Date of 1970 AmendmentAmendment by Pub. L. 91–614 applicable with respect to gifts made after Dec. 31, 1970, see section 102(e) of Pub. L. 91–614, set out as a note under section 2501 of this title.
+
+Effective Date of 1969 AmendmentAmendment by section 101(j)(43), (44) of Pub. L. 91–172 effective Jan. 1, 1970, see section 101(k)(1) of Pub. L. 91–172, set out as an Effective Date note under section 4940 of this title. Amendment by section 960(a) of Pub. L. 91–172 effective one year after Dec. 30, 1969, see section 962(e) of Pub. L. 91–172, set out as an Effective Date note under section 7463 of this title.
+
+Plan Amendments Not Required Until January 1, 1989For provisions directing that if any amendments made by subtitle A or subtitle C of title XI [§§ 1101–1147 and 1171–1177] or title XVIII [§§ 1800–1899A] of Pub. L. 99–514 require an amendment to any plan, such plan amendment shall not be required to be made before the first plan year beginning on or after Jan. 1, 1989, see section 1140 of Pub. L. 99–514, as amended, set out as a note under section 401 of this title.

legal/us/code/title-26/chapter-63/section-6215.md

@@ -0,0 +1,59 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6215"
+description: "Assessment of deficiency found by Tax Court"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6215"
+citation: "26 U.S.C. § 6215"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6215"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "49ed8fa8403b1f12576a8ede81cc51c7cc3d6112c4bbc6b9e7ad8e9708ec7a6e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "5d74193c03aa666b882427bac9df2d87c10c1da61f205ee788b30b4016195119"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6215 - Assessment of deficiency found by Tax Court
+
+## Text
+
+(a) General rule If the taxpayer files a petition with the Tax Court, the entire amount redetermined as the deficiency by the decision of the Tax Court which has become final shall be assessed and shall be paid upon notice and demand from the Secretary. No part of the amount determined as a deficiency by the Secretary but disallowed as such by the decision of the Tax Court which has become final shall be assessed or be collected by levy or by proceeding in court with or without assessment.
+
+(b) Cross references (1) For assessment or collection of the amount of the deficiency determined by the Tax Court pending appellate court review, see section 7485.
+
+(2) For dismissal of petition by Tax Court as affirmation of deficiency as determined by the Secretary, see section 7459(d).
+
+(3) For decision of Tax Court that tax is barred by limitation as its decision that there is no deficiency, see section 7459(e).
+
+(4) For assessment of damages awarded by Tax Court for instituting proceedings merely for delay, see section 6673.
+
+(5) For rules applicable to Tax Court proceedings, see generally subchapter C of chapter 76.
+
+(6) For extension of time for paying amount determined as deficiency, see section 6161(b).
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 773; Pub. L. 94–455, title XIX, § 1906(a)(16), (b)(13)(A), Oct. 4, 1976, 90 Stat. 1825, 1834; Pub. L. 99–514, title XIV, § 1404(c)(2), Oct. 22, 1986, 100 Stat. 2714; Pub. L. 115–141, div. U, title IV, § 401(b)(46), Mar. 23, 2018, 132 Stat. 1204.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2018—Subsec. (b)(5) to (7). Pub. L. 115–141 redesignated pars. (6) and (7) as (5) and (6), respectively, and struck out former par. (5) which read as follows: “For treatment of certain deficiencies as having been paid, in connection with sale of surplus war-built vessels, see section 9(b)(8) of the Merchant Ship Sales Act of 1946 (50 U.S.C. App. 1742).” 1986—Subsec. (b)(7), (8). Pub. L. 99–514 redesignated par. (8) as (7) and struck out former par. (7) which read as follows: “For proration of deficiency to installments, see section 6152(c).” 1976—Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary” wherever appearing. Subsec. (b)(5). Pub. L. 94–455, § 1906(a)(16), struck out “60 Stat. 48;” before “50 U.S.C. App. 1742”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1986 AmendmentAmendment by Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, see section 1404(d) of Pub. L. 99–514, set out as a note under section 643 of this title.
+
+Savings ProvisionFor provisions that nothing in amendment by Pub. L. 115–141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. 23, 2018, for purposes of determining liability for tax for periods ending after Mar. 23, 2018, see section 401(e) of Pub. L. 115–141, set out as a note under section 23 of this title.

legal/us/code/title-26/chapter-63/section-6216.md

@@ -0,0 +1,53 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6216"
+description: "Cross references"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6216"
+citation: "26 U.S.C. § 6216"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6216"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "deaecb11fd675fcbb80aab7f167e7d429c8eaf18cbda3e079c697f9c0e6c0dce"
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+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6216 - Cross references
+
+## Text
+
+(1) For procedures relating to receivership proceedings, see subchapter B of chapter 70.
+
+(2) For procedures relating to jeopardy assessments, see subchapter A of chapter 70.
+
+(3) For procedures relating to claims against transferees and fiduciaries, see chapter 71.
+
+(4) For procedures relating to partnership items, see subchapter C.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 773; Pub. L. 96–589, § 6(i)(9), Dec. 24, 1980, 94 Stat. 3411; Pub. L. 97–248, title IV, § 402(c)(3), Sept. 3, 1982, 96 Stat. 667.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1982—Par. (4). Pub. L. 97–248 added par. (4). 1980—Par. (1). Pub. L. 96–589 struck out reference to bankruptcy proceedings.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1982 AmendmentAmendment by Pub. L. 97–248 applicable to partnership taxable years beginning after Sept. 3, 1982, with provision for the applicability of the amendment to any partnership taxable year ending after Sept. 3, 1982, if the partnership, each partner, and each indirect partner requests such application and the Secretary of the Treasury or his delegate consents to such application, see section 407(a)(1), (3) of Pub. L. 97–248, set out as a note under section 702 of this title.
+
+Effective Date of 1980 AmendmentAmendment by Pub. L. 96–589 effective Oct. 1, 1979, but not applicable to proceedings under Title 11, Bankruptcy, commenced before Oct. 1, 1979, see section 7(e) of Pub. L. 96–589, set out as a note under section 108 of this title.

legal/us/code/title-26/chapter-63/section-6221.md

@@ -0,0 +1,75 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6221"
+description: "Determination at partnership level"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6221"
+citation: "26 U.S.C. § 6221"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6221"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "e8eea112b94d88d718cb32c2533ff5c0e9ce368c7317bb874b4982af9f293fd7"
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+text_hash: "01c882f52b60e0f6851729685a1a2525264d74ff9ad55e82e1bd577ed7cb4292"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6221 - Determination at partnership level
+
+## Text
+
+(a) In general Any adjustment to a partnership-related item shall be determined, and any tax attributable thereto shall be assessed and collected, and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to any such item shall be determined, at the partnership level, except to the extent otherwise provided in this subchapter.
+
+(b) Election out for certain partnerships with 100 or fewer partners, etc. (1) In general This subchapter shall not apply with respect to any partnership for any taxable year if—
+
+(A) the partnership elects the application of this subsection for such taxable year,
+
+(B) for such taxable year the partnership is required to furnish 100 or fewer statements under section 6031(b) with respect to its partners,
+
+(C) each of the partners of such partnership is an individual, a C corporation, any foreign entity that would be treated as a C corporation were it domestic, an S corporation, or an estate of a deceased partner,
+
+(D) the election—
+
+(i) is made with a timely filed return for such taxable year, and
+
+(ii) includes (in the manner prescribed by the Secretary) a disclosure of the name and taxpayer identification number of each partner of such partnership, and
+
+(E) the partnership notifies each such partner of such election in the manner prescribed by the Secretary.
+
+(2) Special rules relating to certain partners (A) S corporation partners In the case of a partner that is an S corporation—
+
+(i) the partnership shall only be treated as meeting the requirements of paragraph (1)(C) with respect to such partner if such partnership includes (in the manner prescribed by the Secretary) a disclosure of the name and taxpayer identification number of each person with respect to whom such S corporation is required to furnish a statement under section 6037(b) for the taxable year of the S corporation ending with or within the partnership taxable year for which the application of this subsection is elected, and
+
+(ii) the statements such S corporation is required to so furnish shall be treated as statements furnished by the partnership for purposes of paragraph (1)(B).
+
+(B) Foreign partners For purposes of paragraph (1)(D)(ii), the Secretary may provide for alternative identification of any foreign partners.
+
+(C) Other partners The Secretary may by regulation or other guidance prescribe rules similar to the rules of subparagraph (A) with respect to any partners not described in such subparagraph or paragraph (1)(C).
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 625; amended Pub. L. 115–141, div. U, title II, § 201(c)(2), Mar. 23, 2018, 132 Stat. 1173.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6221, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 648; amended Pub. L. 105–34, title XII, § 1238(a), Aug. 5, 1997, 111 Stat. 1026, related to tax treatment determined at partnership level, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141 amended subsec. (a) generally. Prior to amendment, text read as follows: “Any adjustment to items of income, gain, loss, deduction, or credit of a partnership for a partnership taxable year (and any partner’s distributive share thereof) shall be determined, any tax attributable thereto shall be assessed and collected, and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to any such item or share shall be determined, at the partnership level pursuant to this subchapter.”
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DatePub. L. 114–74, title XI, § 1101(g), Nov. 2, 2015, 129 Stat. 638, provided that: “(1) In general.—Except as otherwise provided in this subsection, the amendments made by this section [enacting this subchapter, amending sections 6031, 6330, 6422, 6501, 6503, 6504, 6511, 6512, 6515, 6601, 7421, 7422, 7459, 7482, and 7485 of this title, and repealing this subchapter, subchapter D of this chapter, and part IV of subchapter K of chapter 1 of this title] shall apply to returns filed for partnership taxable years beginning after December 31, 2017. “(2) Administrative adjustment requests.—In the case of [an] administrative adjustment request under section 6227 of such Code [Internal Revenue Code of 1986], the amendments made by this section shall apply to requests with respect to returns filed for partnership taxable years beginning after December 31, 2017. “(3) Adjusted partners statements.—In the case of a partnership electing the application of section 6226 of such Code, the amendments made by this section shall apply to elections with respect to returns filed for partnership taxable years beginning after December 31, 2017. “(4) Election.—A partnership may elect (at such time and in such form and manner as the Secretary of the Treasury may prescribe) for the amendments made by this section (other than the election under section 6221(b) of such Code (as added by this Act)) to apply to any return of the partnership filed for partnership taxable years beginning after the date of the enactment of this Act [Nov. 2, 2015] and before January 1, 2018.”

legal/us/code/title-26/chapter-63/section-6222.md

@@ -0,0 +1,71 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6222"
+description: "Partner’s return must be consistent with partnership return"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6222"
+citation: "26 U.S.C. § 6222"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6222"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "9ac342f40d8849c0bd488e319298905798a3e5677851ec6c8df3321540f9e45d"
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+text_hash: "8f3eb46dc208a3c16b4e039e2143b22483da0df09a08cacff7562a10999f4986"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6222 - Partner’s return must be consistent with partnership return
+
+## Text
+
+(a) In general A partner shall, on the partner’s return, treat any partnership-related item in a manner which is consistent with the treatment of such item on the partnership return.
+
+(b) Underpayment due to inconsistent treatment assessed as math error Any underpayment of tax by a partner by reason of failing to comply with the requirements of subsection (a) shall be assessed and collected in the same manner as if such underpayment were on account of a mathematical or clerical error appearing on the partner’s return. Paragraph (2) of section 6213(b) shall not apply to any assessment of an underpayment referred to in the preceding sentence.
+
+(c) Exception for notification of inconsistent treatment (1) In general In the case of any item referred to in subsection (a), if—
+
+(A) (i) the partnership has filed a return but the partner’s treatment on the partner’s return is (or may be) inconsistent with the treatment of the item on the partnership return, or
+
+(ii) the partnership has not filed a return, and
+
+(B) the partner files with the Secretary a statement identifying the inconsistency,
+
+subsections (a) and (b) shall not apply to such item.
+
+(2) Partner receiving incorrect information A partner shall be treated as having complied with subparagraph (B) of paragraph (1) with respect to an item if the partner—
+
+(A) demonstrates to the satisfaction of the Secretary that the treatment of the item on the partner’s return is consistent with the treatment of the item on the statement furnished to the partner by the partnership, and
+
+(B) elects to have this paragraph apply with respect to that item.
+
+(d) Final decision on certain positions not binding on partnership Any final decision with respect to an inconsistent position identified under subsection (c) in a proceeding to which the partnership is not a party shall not be binding on the partnership.
+
+(e) Addition to tax for failure to comply with section For addition to tax in the case of a partner’s disregard of the requirements of this section, see part II of subchapter A of chapter 68.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 626; amended Pub. L. 115–141, div. U, title II, § 201(c)(3), Mar. 23, 2018, 132 Stat. 1173.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6222, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 648; amended Pub. L. 99–514, title XV, § 1503(c)(1), Oct. 22, 1986, 100 Stat. 2743; Pub. L. 101–239, title VII, § 7721(c)(7), Dec. 19, 1989, 103 Stat. 2400, required partner’s return to be consistent with partnership return or Secretary to be notified of inconsistency, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141 amended subsec. (a) generally. Prior to amendment, text read as follows: “A partner shall, on the partner’s return, treat each item of income, gain, loss, deduction, or credit attributable to a partnership in a manner which is consistent with the treatment of such income, gain, loss, deduction, or credit on the partnership return.”
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DateSection 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.

legal/us/code/title-26/chapter-63/section-6223.md

@@ -0,0 +1,51 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6223"
+description: "Partners bound by actions of partnership"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6223"
+citation: "26 U.S.C. § 6223"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6223"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "91a7354a3c5b0426206f8bcae8e7875b627c667279936d320b47145c2e93a0b4"
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+text_hash: "330cfd628ab078a7372e6c4011fd48b51de5d7beb8dffc458dcfc77de697d869"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6223 - Partners bound by actions of partnership
+
+## Text
+
+(a) Designation of partnership representative Each partnership shall designate (in the manner prescribed by the Secretary) a partner (or other person) with a substantial presence in the United States as the partnership representative who shall have the sole authority to act on behalf of the partnership under this subchapter. In any case in which such a designation is not in effect, the Secretary may select any person as the partnership representative.
+
+(b) Binding effect A partnership and all partners of such partnership shall be bound—
+
+(1) by actions taken under this subchapter by the partnership, and
+
+(2) by any final decision in a proceeding brought under this subchapter with respect to the partnership.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 627.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsPrior sections 6223 and 6224 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 6223, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 649, related to notice to partners of proceedings. Section 6224, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 651; amended Pub. L. 107–147, title IV, § 416(d)(1)(A), Mar. 9, 2002, 116 Stat. 55, related to partner participation in administrative proceedings, waiver of partner’s rights, and settlement agreements.
+
+Statutory Notes and Related Subsidiaries
+
+Effective DateSection 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.

legal/us/code/title-26/chapter-63/section-6225.md

@@ -0,0 +1,167 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6225"
+description: "Partnership adjustment by Secretary"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6225"
+citation: "26 U.S.C. § 6225"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6225"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "694c6cf1ca340e5f6d1f65de41fd888369c460b24c3eec86dc757ceb7e2209b6"
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+text_hash: "684345c80228167bf3d64692518126177fb091f4da796c2a907c4ce09e00bfbc"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6225 - Partnership adjustment by Secretary
+
+## Text
+
+(a) In general In the case of any adjustments by the Secretary to any partnership-related items with respect to any reviewed year of a partnership—
+
+(1) if such adjustments result in an imputed underpayment, the partnership shall pay an amount equal to such imputed underpayment in the adjustment year as provided in section 6232, and
+
+(2) if such adjustments do not result in an imputed underpayment, such adjustments shall be taken into account by the partnership in the adjustment year.
+
+(b) Determination of imputed underpayments For purposes of this subchapter—
+
+(1) In general Except as otherwise provided in this section, any imputed underpayment with respect to any reviewed year shall be determined by the Secretary by—
+
+(A) appropriately netting all partnership adjustments with respect to such reviewed year, and
+
+(B) applying the highest rate of tax in effect for the reviewed year under section 1 or 11.
+
+(2) Adjustments to distributive shares of partners not netted In the case of any adjustment which reallocates the distributive share of any item from one partner to another, such adjustment shall be taken into account by disregarding so much of such adjustment as results in a decrease in the amount of the imputed underpayment.
+
+(3) Adjustments separately netted by category For purposes of paragraph (1)(A), partnership adjustments for any reviewed year shall first be separately determined (and netted as appropriate) within each category of items that are required to be taken into account separately under section 702(a) or other provision of this title.
+
+(4) Limitation on adjustments that may be taken into account If any adjustment would (but for this paragraph)—
+
+(A) result in a decrease in the amount of the imputed underpayment, and
+
+(B) could be subject to any additional limitation under the provisions of this title (or not allowed, in whole or in part, against ordinary income) if such adjustment were taken into account by any person,
+
+such adjustment shall not be taken into account under paragraph (1)(A) except to the extent otherwise provided by the Secretary.
+
+(c) Modification of imputed underpayments (1) In general The Secretary shall establish procedures under which the imputed underpayment amount may be modified consistent with the requirements of this subsection.
+
+(2) Procedures for partners to take adjustments into account (A) Amended returns of partners Such procedures shall provide that if—
+
+(i) one or more partners file returns for the taxable year of the partners which includes the end of the reviewed year of the partnership (and for any taxable year with respect to which any tax attribute is affected by reason of any adjustment referred to in clause (ii)),
+
+(ii) such returns take into account all adjustments under subsection (a) properly allocable to such partners (and the effect of such adjustments on any tax attributes), and
+
+(iii) payment of any tax due is included with such returns,
+
+then the imputed underpayment amount shall be determined without regard to the portion of the adjustments so taken into account.
+
+(B) Alternative procedure to filing amended returns Such procedures shall provide that, with respect to any partner referred to in subparagraph (A), the requirements of subparagraph (A) shall be treated as satisfied with respect to adjustments properly allocable to such partner if, in lieu of filing the returns described in such subparagraph—
+
+(i) the amounts described in subparagraph (A)(iii) are paid by the partner,
+
+(ii) the partner agrees to take into account, in the form and manner prescribed by the Secretary, the adjustments to the tax attributes of such partner referred to in subparagraph (A)(ii), and
+
+(iii) such partner provides, in the form and manner specified by the Secretary (including, if the Secretary so specifies, in the same form as on an amended return), such information as the Secretary may require to carry out this subparagraph.
+
+(C) Reallocation of distributive share In the case of any adjustment which reallocates the distributive share of any item from one partner to another, this paragraph shall apply with respect to any such partner only if the requirements of subparagraph (A) or (B) are satisfied with respect to all partners affected by such adjustment.
+
+(D) Application of statute of limitations In the case of adjustments referred to in subparagraph (A)(ii), sections 6501 and 6511 shall not apply with respect to any return filed for purposes of subparagraph (A)(i) or any amount paid under subparagraph (A)(iii) or (B)(i).
+
+(E) Adjustments to tax attributes binding for affected taxable years of partner The adjustments to the tax attributes of any partner provided for in subparagraph (A)(ii) or (B)(ii) shall be binding with respect to the taxable year of the partner which includes the end of the reviewed year of the partnership and any taxable years for which any tax attribute is affected by such adjustment. Any failure to so treat any such tax attribute shall be treated for purposes of this title in the same manner as a failure to treat a partnership-related item in a manner which is consistent with the treatment of such item on the partnership return within the meaning of section 6222.
+
+(F) 11 So in original. Two subpars. (F) have been enacted. Application to partnerships and S corporations in tiered structures (i) In general 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) Treatment of S corporations For purposes of clause (i), an S corporation and its shareholders shall be treated in the same manner as a partnership and its partners.
+
+(F) 1 Adjustments not treated as amended return An administrative adjustment request under section 6227 and a partnership adjustment tracking report under section 6226(b)(4)(A) shall not be treated as a return for purposes of this paragraph.
+
+(3) Tax-exempt partners Such procedures shall provide for determining the imputed underpayment without regard to the portion of the adjustment that the partnership demonstrates is allocable to a partner that would not owe tax by reason of its status as a tax-exempt entity (as defined in section 168(h)(2)).
+
+(4) Modification of applicable highest tax rates (A) In general Such procedures shall provide for taking into account a rate of tax lower than the rate of tax described in subsection (b)(1)(A) with respect to any portion of the adjustment that the partnership demonstrates is allocable to a partner which—
+
+(i) is a C corporation, or
+
+(ii) in the case of a capital gain or qualified dividend, is an individual.
+
+In no event shall the lower rate determined under the preceding sentence be less than the highest rate in effect with respect to the income and taxpayer described in clause (i) or clause (ii), as the case may be. For purposes of clause (ii), an S corporation shall be treated as an individual.
+
+(B) Portion of imputed underpayment to which lower rate applies (i) In general Except as provided in clause (ii), the portion of the imputed underpayment to which the lower rate applies with respect to a partner under subparagraph (A) shall be determined by reference to the partners’ distributive share of items to which the imputed underpayment relates.
+
+(ii) Rule in case of varied treatment of items among partners If the imputed underpayment is attributable to the adjustment of more than 1 item, and any partner’s distributive share of such items is not the same with respect to all such items, then the portion of the imputed underpayment to which the lower rate applies with respect to a partner under subparagraph (A) shall be determined by reference to the amount which would have been the partner’s distributive share of net gain or loss if the partnership had sold all of its assets at their fair market value as of the close of the reviewed year of the partnership.
+
+(5) Certain passive losses of publicly traded partnerships (A) In general In the case of a publicly traded partnership (as defined in section 469(k)(2)), such procedures shall provide—
+
+(i) for determining the imputed underpayment without regard to the portion of the adjustment that the partnership demonstrates is attributable to a net decrease in a specified passive activity loss which is allocable to a specified partner, and
+
+(ii) for the partnership to take such net decrease into account as an adjustment in the adjustment year with respect to the specified partners to which such net decrease relates.
+
+(B) Specified passive activity loss For purposes of this paragraph, the term “specified passive activity loss” means, with respect to any specified partner of such publicly traded partnership, the lesser of—
+
+(i) the passive activity loss of such partner which is separately determined with respect to such partnership under section 469(k) with respect to such partner’s taxable year in which or with which the reviewed year of such partnership ends, or
+
+(ii) such passive activity loss so determined with respect to such partner’s taxable year in which or with which the adjustment year of such partnership ends.
+
+(C) Specified partner For purposes of this paragraph, the term “specified partner” means any person if such person—
+
+(i) is a partner of the publicly traded partnership referred to in subparagraph (A),
+
+(ii) is described in section 469(a)(2), and
+
+(iii) has a specified passive activity loss with respect to such publicly traded partnership,
+
+with respect to each taxable year of such person which is during the period beginning with the taxable year of such person in which or with which the reviewed year of such publicly traded partnership ends and ending with the taxable year of such person in which or with which the adjustment year of such publicly traded partnership ends.
+
+(6) Other procedures for modification of imputed underpayment The Secretary may by regulations or guidance provide for additional procedures to modify imputed underpayment amounts on the basis of such other factors as the Secretary determines are necessary or appropriate to carry out the purposes of this subsection.
+
+(7) Year and day for submission to Secretary Anything required to be filed or submitted under this subsection shall be submitted to the Secretary not later than the close of the 270-day period beginning on the date on which the notice of a proposed partnership adjustment is mailed under section 6231 unless such period is extended with the consent of the Secretary.
+
+(8) Decision of Secretary Any modification of the imputed underpayment amount under this subsection shall be made only upon approval of such modification by the Secretary.
+
+(9) Modification of adjustments not resulting in an imputed underpayment The Secretary shall establish procedures under which the adjustments described in subsection (a)(2) may be modified in such manner as the Secretary determines appropriate.
+
+(d) Definitions For purposes of this subchapter—
+
+(1) Reviewed year The term “reviewed year” means the partnership taxable year to which the item being adjusted relates.
+
+(2) Adjustment year The term “adjustment year” means the partnership taxable year in which—
+
+(A) in the case of an adjustment pursuant to the decision of a court in a proceeding brought under section 6234, such decision becomes final,
+
+(B) in the case of an administrative adjustment request under section 6227, such administrative adjustment request is made, or
+
+(C) in any other case, notice of the final partnership adjustment is mailed under section 6231.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 628; amended Pub. L. 114–113, div. Q, title IV, § 411(a), Dec. 18, 2015, 129 Stat. 3121; Pub. L. 115–141, div. U, title II, §§ 202, 203(a), 206(b), (p)(1), Mar. 23, 2018, 132 Stat. 1173, 1174, 1178, 1182.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6225, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 652; amended Pub. L. 105–34, title XII, § 1239(a), Aug. 5, 1997, 111 Stat. 1027, allowing assessments to be made only after partnership level proceedings were completed, was repealed by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141, § 202(c)(1), amended subsec. (a) generally. Prior to amendment, subsec. (a) related to adjustment by the Secretary in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share thereof. Subsec. (b). Pub. L. 115–141, § 202(a), amended subsec. (b) generally. Prior to amendment, subsec. (b) consisted of pars. (1) and (2) relating to determination of imputed underpayments in general and adjustments to distributive shares of partners not netted, respectively. Subsec. (c)(2). Pub. L. 115–141, § 203(a), amended par. (2) generally. Prior to amendment, par. (2) related to amended returns of partners. Subsec. (c)(2)(F). Pub. L. 115–141, § 206(b), added subpar. (F) relating to adjustments not treated as amended return. Subsec. (c)(3). Pub. L. 115–141, § 202(b)(1), substituted “without regard to the portion of the adjustment” for “without regard to the portion thereof”. Subsec. (c)(4)(A). Pub. L. 115–141, § 202(b)(2), substituted “with respect to any portion of the adjustment” for “with respect to any portion of the imputed underpayment” in introductory provisions. Subsec. (c)(5)(A)(i). Pub. L. 115–141, § 202(b)(3), substituted “without regard to the portion of the adjustment” for “without regard to the portion thereof”. Subsec. (c)(7). Pub. L. 115–141, § 206(p)(1), substituted “filed or submitted under this subsection” for “submitted pursuant to paragraph (1)”. Subsec. (c)(9). Pub. L. 115–141, § 202(c)(2), added par. (9). 2015—Subsec. (c)(4)(A)(i). Pub. L. 114–113, § 411(a)(1), struck out “in the case of ordinary income,” before “is a C corporation”. Subsec. (c)(5) to (8). Pub. L. 114–113, § 411(a)(2), added par. (5) and redesignated former pars. (5) to (7) as (6) to (8), respectively.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 of 2015 AmendmentAmendment by Pub. L. 114–113 effective as if included in section 1101 of Pub. L. 114–74, see section 411(e) of Pub. L. 114–113, set out as a note under section 6031 of this title.
+
+Effective DateSection 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.

legal/us/code/title-26/chapter-63/section-6226.md

@@ -0,0 +1,99 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6226"
+description: "Alternative to payment of imputed underpayment by partnership"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6226"
+citation: "26 U.S.C. § 6226"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6226"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "0a9e5618363760aad370cd8a8c460917c32975a646d390c7da2aaecc59183f08"
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+text_hash: "4e09f0a6cfdb5c912ede735d2a4c2753fbf34bd255ca1bab504f3571f6b27ea8"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6226 - Alternative to payment of imputed underpayment by partnership
+
+## Text
+
+(a) In general If the partnership—
+
+(1) not later than 45 days after the date of the notice of final partnership adjustment, elects the application of this section with respect to an imputed underpayment, and
+
+(2) at such time and in such manner as the Secretary may provide, furnishes to each partner of the partnership for the reviewed year and to the Secretary a statement of the partner’s share of any adjustment to a partnership-related item (as determined in the notice of final partnership adjustment),
+
+section 6225 shall not apply with respect to such underpayment (and no assessment of tax, levy, or proceeding in any court for the collection of such underpayment shall be made against such partnership) and each such partner shall take such adjustment into account as provided in subsection (b). The election under paragraph (1) shall be made in such manner as the Secretary may provide and, once made, shall be revocable only with the consent of the Secretary.
+
+(b) Adjustments taken into account by partner (1) Tax imposed in year of statement Except as provided in paragraph (4), each partner’s tax imposed by chapter 1 for the taxable year which includes the date the statement was furnished under subsection (a) shall be adjusted by the aggregate of the correction amounts determined under paragraph (2) for the taxable years referred to therein.
+
+(2) Correction amounts The correction amounts determined under this paragraph are—
+
+(A) in the case of the taxable year of the partner which includes the end of the reviewed year, the amount by which the tax imposed under chapter 1 would increase or decrease if the partner’s share of the adjustments described in subsection (a) were taken into account for such taxable year, and
+
+(B) in the case of any taxable year after the taxable year referred to in subparagraph (A) and before the taxable year referred to in paragraph (1), the amount by which the tax imposed under chapter 1 would increase or decrease by reason of the adjustment to tax attributes under paragraph (3).
+
+(3) Adjustment of tax attributes Any tax attribute which would have been affected if the adjustments described in subsection (a) were taken into account for the taxable year referred to in paragraph (2)(A) shall—
+
+(A) in the case of any taxable year referred to in paragraph (2)(B), be appropriately adjusted for purposes of applying such paragraph, and
+
+(B) in the case of any subsequent taxable year, be appropriately adjusted.
+
+(4) Treatment of partnerships and S corporations in tiered structures (A) In general If a partner which receives a statement under subsection (a)(2) is a partnership or an S corporation, such partner shall, with respect to the partner’s share of the adjustment—
+
+(i) file with the Secretary a partnership adjustment tracking report which includes such information as the Secretary may require, and
+
+(ii) (I) furnish statements under rules similar to the rules of subsection (a)(2), or
+
+(II) if no such statements are furnished, compute and pay an imputed underpayment under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof).
+
+(B) Due date For purposes of subparagraph (A), with respect to a partner’s share of the adjustment, the partnership adjustment tracking report shall be filed, and the imputed underpayment shall be paid or statements shall be furnished, not later than the due date for the return for the adjustment year of the audited partnership.
+
+(C) Partnership payment of tax if elected out of subchapter 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.
+
+(D) Audited partnership For purposes of this paragraph, the term “audited partnership” means, with respect to any partner described in subparagraph (A), the partnership in the chain of ownership originally electing the application of this section.
+
+(E) Treatment of trusts The Secretary shall prescribe such rules as may be necessary with respect to trusts which receive a statement under subsection (a)(2).
+
+(c) Penalties and interest (1) Penalties 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.
+
+(2) Interest In the case of an imputed underpayment with respect to which the application of this section is elected, or which is described in subsection (b)(4)(A)(ii)(I), interest shall be determined—
+
+(A) at the partner level,
+
+(B) from the due date of the return for the taxable year to which the increase is attributable (determined by taking into account any increases attributable to a change in tax attributes for a taxable year under subsection (b)(2)), and
+
+(C) at the underpayment rate under section 6621(a)(2), determined by substituting “5 percentage points” for “3 percentage points” in subparagraph (B) thereof.
+
+(d) Judicial review For the time period within which a partnership may file a petition for a readjustment, see section 6234(a).
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 630; amended Pub. L. 114–113, div. Q, title IV, § 411(b)(1), Dec. 18, 2015, 129 Stat. 3122; Pub. L. 115–141, div. U, title II, §§ 201(c)(4), 204, 206(d), (e), Mar. 23, 2018, 132 Stat. 1173, 1176, 1178.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6226, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 653; amended Pub. L. 97–448, title III, § 306(c)(1)(A), Jan. 12, 1983, 96 Stat. 2406; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 105–34, title XII, §§ 1238(b)(1), 1239(b), 1240(a), Aug. 5, 1997, 111 Stat. 1026–1028, related to judicial review of final partnership administrative adjustments, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141, § 206(d), inserted “(and no assessment of tax, levy, or proceeding in any court for the collection of such underpayment shall be made against such partnership)” after “section 6225 shall not apply with respect to such underpayment” in concluding provisions. Subsec. (a)(2). Pub. L. 115–141, § 201(c)(4), substituted “any adjustment to a partnership-related item” for “any adjustment to income, gain, loss, deduction, or credit”. Subsec. (b)(1). Pub. L. 115–141, § 206(e)(2), substituted “correction amounts” for “adjustment amounts”. Pub. L. 115–141, § 206(e)(1), substituted “adjusted” for “increased”. Pub. L. 115–141, § 204(b)(1), substituted “Except as provided in paragraph (4), each partner’s” for “Each partner’s”. Subsec. (b)(2). Pub. L. 115–141, § 206(e)(5), substituted “Correction amounts” for “Adjustment amounts” in heading. Pub. L. 115–141, § 206(e)(3), substituted “increase or decrease” for “increase” in subpars. (A) and (B). Pub. L. 115–141, § 206(e)(2), substituted “correction amounts” for “adjustment amounts” in introductory provisions. Subsec. (b)(2)(A). Pub. L. 115–141, § 206(e)(4), substituted “and” for “plus” at end. Subsec. (b)(4). Pub. L. 115–141, § 204(a), added par. (4). Subsec. (c)(2). Pub. L. 115–141, § 204(b)(2), inserted “or which is described in subsection (b)(4)(A)(ii)(I),” after “is elected,” in introductory provisions. 2015—Subsec. (d). Pub. L. 114–113 added subsec. (d).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 of 2015 AmendmentAmendment by Pub. L. 114–113 effective as if included in section 1101 of Pub. L. 114–74, see section 411(e) of Pub. L. 114–113, set out as a note under section 6031 of this title.
+
+Effective DateSection 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.

legal/us/code/title-26/chapter-63/section-6227.md

@@ -0,0 +1,67 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6227"
+description: "Administrative adjustment request by partnership"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6227"
+citation: "26 U.S.C. § 6227"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6227"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "470785da3efabff207fc63c8beba6a61a6ca0a79379c2e391cd7a2bf87b618c8"
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+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6227 - Administrative adjustment request by partnership
+
+## Text
+
+(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.
+
+(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—
+
+(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
+
+(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).
+
+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).
+
+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).
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 631; amended Pub. L. 115–141, div. U, title II, §§ 201(c)(5), 206(f), (p)(2), (3), Mar. 23, 2018, 132 Stat. 1173, 1179, 1182.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsPrior 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.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141, § 201(c)(5), substituted “partnership-related items” for “items of income, gain, loss, deduction, or credit of the partnership”. Subsec. (b). Pub. L. 115–141, § 206(p)(2), substituted “is filed” for “is made” in introductory provisions and in par. (1). Subsec. (b)(1). 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. Subsec. (d). Pub. L. 115–141, § 206(f), added subsec. (d).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DateSection 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.

legal/us/code/title-26/chapter-63/section-6231.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6231"
+description: "Notice of proceedings and adjustment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6231"
+citation: "26 U.S.C. § 6231"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6231"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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+text_hash: "3412f3ae1f77ebe53a9b46c93408699c6731bca62f63885e56e30dd060df6744"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6231 - Notice of proceedings and adjustment
+
+## Text
+
+(a) In general The Secretary shall mail to the partnership and the partnership representative—
+
+(1) notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any partnership-related item for any partnership taxable year, or any partner’s distributive share thereof,
+
+(2) notice of any proposed partnership adjustment resulting from such proceeding, and
+
+(3) notice of any final partnership adjustment resulting from such proceeding.
+
+Any notice of a final partnership adjustment shall be sufficient if mailed to the last known address of the partnership representative or the partnership (even if the partnership has terminated its existence). The first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a partnership under section 6227.
+
+(b) Timing of notices (1) Notice of proposed partnership adjustment Any notice of a proposed partnership adjustment shall not be mailed later than the date determined under section 6235 (determined without regard to paragraphs (2) and (3) of subsection (a) thereof).
+
+(2) Notice of final partnership adjustment (A) In general Except to the extent that the partnership elects to waive the application of this subparagraph, 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.
+
+(B) Statute of limitations on adjustment For the period of limitations on making adjustments, see section 6235.
+
+(c) Further notices restricted If the Secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section 6234 with respect to such notice, in the absence of a showing of fraud, malfeasance, or misrepresentation of a material fact, the Secretary shall not mail another such notice to such partnership with respect to such taxable year.
+
+(d) Authority to rescind notice with partnership consent The Secretary may, with the consent of the partnership, rescind any notice of a partnership adjustment mailed to such partnership. Any notice so rescinded shall not be treated as a notice of a partnership adjustment for purposes of this subchapter, and the taxpayer shall have no right to bring a proceeding under section 6234 with respect to such notice.
+
+(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 ProvisionsA 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.
+
+Amendments2018—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 AmendmentAmendment 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 DateSection 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 PartnershipsPub. 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.”

legal/us/code/title-26/chapter-63/section-6232.md

@@ -0,0 +1,93 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6232"
+description: "Assessment, collection, and payment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6232"
+citation: "26 U.S.C. § 6232"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6232"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "f8d5f10da6c394f312346ccc889708d4e1955d83a10c788f6479cc3e762f7b22"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "a4153e71932310f10e65589d905dac374b3722ecbe1829d39ed0d193cb1d4416"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6232 - Assessment, collection, and payment
+
+## Text
+
+(a) In general Any imputed underpayment shall be assessed and collected in the same manner as if it were a tax imposed for the adjustment year by subtitle A, except that—
+
+(1) subchapter B of chapter 63 shall not apply, and
+
+(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.
+
+(b) Limitation on assessment Except as otherwise provided in this subtitle (other than subchapter B of this chapter), no assessment of an imputed underpayment may be made (and no levy or proceeding in any court for the collection of any amount resulting from such adjustment may be made, begun or prosecuted) before—
+
+(1) the close of the 90th day after the day on which a notice of a final partnership adjustment was mailed, and
+
+(2) if a petition is filed under section 6234 with respect to such notice, the decision of the court has become final.
+
+The preceding sentence shall not apply in the case of a specified similar amount (as defined in subsection (f)(2)).
+
+(c) Premature action may be enjoined Notwithstanding section 7421(a), any action which violates subsection (b) may be enjoined in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction to enjoin any action under this subsection unless a timely petition has been filed under section 6234 and then only in respect of the adjustments that are the subject of such petition.
+
+(d) Exceptions to restrictions on adjustments (1) Adjustments arising out of math or clerical errors (A) In general If the partnership is notified that, on account of a mathematical or clerical error appearing on the partnership return, an adjustment to an item is required, rules similar to the rules of paragraphs (1) and (2) of section 6213(b) shall apply to such adjustment.
+
+(B) Special rule If a partnership is a partner in another partnership, any adjustment on account of such partnership’s failure to comply with the requirements of section 6222(a) with respect to its interest in such other partnership shall be treated as an adjustment referred to in subparagraph (A), except that paragraph (2) of section 6213(b) shall not apply to such adjustment.
+
+(2) Partnership may waive restrictions The partnership may at any time (whether or not any notice of partnership adjustment has been issued), by a signed notice in writing filed with the Secretary, waive the restrictions provided in subsection (b) on the making of any partnership adjustment.
+
+(e) Limit where no proceeding begun If no proceeding under section 6234 is begun with respect to any notice of a final partnership adjustment during the 90-day period described in subsection (b), the amount for which the partnership is liable under section 6225 shall not exceed the amount determined in accordance with such notice.
+
+(f) Failure to pay imputed underpayment (1) In general If any amount of any imputed underpayment to which section 6225 applies or any specified similar amount (or any interest or penalties with respect to any such amount) has not been paid by the date which is 10 days after the date on which the Secretary provides notice and demand for such payment—
+
+(A) section 6621(a)(2)(B) shall be applied by substituting “5 percentage points” for “3 percentage points” with respect to such amount, and
+
+(B) the Secretary may assess upon each partner of the partnership (determined as of the close of the adjustment year or, if the partnership has ceased to exist as of such time, the former partners of the partnership as determined for purposes of section 6241(7)) a tax equal to such partner’s proportionate share of such amount (including any such interest or penalties, determined after application of subparagraph (A)).
+
+(2) Specified similar amount For purposes of this subsection, the term “specified similar amount” means—
+
+(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
+
+(B) any amount assessed under paragraph (1)(B) upon a partner which is a partnership.
+
+(3) Proportionate share For purposes of paragraph (1), a partner’s proportionate share is such percentage as the Secretary may determine on the basis of such partner’s distributive share. The Secretary shall make determinations under the preceding sentence such that the aggregate proportionate shares so determined total 100 percent.
+
+(4) Coordination with partnership liability The liability of the partnership for any amount with respect to which a partner is made liable under paragraph (1) shall be reduced upon payment by the partner of such amount. Paragraph (1)(B) shall not apply with respect to any amount after the date on which such amount is paid by the partnership.
+
+(5) S corporations For purposes of this subsection, an S corporation and its shareholders shall be treated in the same manner as a partnership and its partners.
+
+(6) Rules related to assessment and collection (A) Deficiency procedures not applicable Subchapter B shall not apply to any assessment or collection under this paragraph.
+
+(B) Limitation on assessment Except as otherwise provided in this subtitle, no assessment may be made (or proceeding in court begun without assessment) with respect to any partner with respect to an amount under paragraph (1) after the date which is 2 years after the date on which the Secretary provides the notice and demand referred to in paragraph (1) with respect to such amount.
+
+(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, §§ 205(a), 206(g), (p)(4)–(6), Mar. 23, 2018, 132 Stat. 1177, 1179, 1182.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6232, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 666, related to extension of subchapter provisions, respecting tax treatment of partnership items, to windfall profit tax, prior to repeal by Pub. L. 100–418, title I, § 1941(b)(1), Aug. 23, 1988, 102 Stat. 1323.
+
+Amendments2018—Subsec. (a). Pub. L. 115–141, § 206(g)(1), substituted “except that—” for “except that in the case of an administrative adjustment request to which section 6227(b)(1) applies, the underpayment shall be paid when the request is filed.” and added pars. (1) and (2). Subsec. (b). Pub. L. 115–141, § 206(p)(4), substituted “this subtitle (other than subchapter B of this chapter)” for “this chapter” in introductory provisions. Pub. L. 115–141, § 206(g)(2), substituted “assessment of an imputed underpayment” for “assessment of a deficiency” in introductory provisions and inserted concluding provisions. Subsec. (d)(1)(A). Pub. L. 115–141, § 206(p)(5), substituted “an item” for “a item”. Subsec. (e). Pub. L. 115–141, § 206(p)(6), struck out “thereof” after “subsection (b)”. Subsec. (f). Pub. L. 115–141, § 205(a), added subsec. (f).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DateSection 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.

legal/us/code/title-26/chapter-63/section-6233.md

@@ -0,0 +1,73 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6233"
+description: "Interest and penalties"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6233"
+citation: "26 U.S.C. § 6233"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6233"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "6a67b774774430d98f9a32c8acdc3dcbad27b86773fa6785a779e819cff7f65b"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e3a5d3bfd3ba10b36902a86b1024c749c56414073774cf833bfcc348a128d61a"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6233 - Interest and penalties
+
+## Text
+
+(a) Interest and penalties determined from reviewed year (1) In general 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).
+
+(2) Determination of amount of interest The interest computed under this paragraph with respect to any partnership adjustment is the interest which would be determined under chapter 67 for the period beginning on the day after the return due date for the reviewed year and ending on the return due date for the adjustment year (or, if earlier, the date payment of the imputed underpayment is made). Proper adjustments in the amount determined under the preceding sentence shall be made for adjustments required for partnership taxable years after the reviewed year and before the adjustment year by reason of such partnership adjustment.
+
+(3) Penalties Any penalty, addition to tax, or additional amount shall be determined at the partnership level as if such partnership had been an individual subject to tax under chapter 1 for the reviewed year and the imputed underpayment were an actual underpayment (or understatement) for such year.
+
+(b) Interest and penalties with respect to adjustment year return (1) In general In the case of any failure to pay an imputed underpayment on the date prescribed therefor, the partnership shall be liable—
+
+(A) for interest as determined under paragraph (2), and
+
+(B) for any penalty, addition to tax, or additional amount as determined under paragraph (3).
+
+(2) Interest Interest determined under this paragraph is the interest that would be determined by treating the imputed underpayment as an underpayment of tax imposed in the adjustment year.
+
+(3) Penalties Penalties, additions to tax, or additional amounts determined under this paragraph are the penalties, additions to tax, or additional amounts that would be determined—
+
+(A) by applying section 6651(a)(2) to such failure to pay, and
+
+(B) by treating the imputed underpayment as an underpayment of tax for purposes of part II of subchapter A of chapter 68.
+
+(c) Deposit to suspend interest For rules allowing deposits to suspend running of interest on potential underpayments, see section 6603.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 633; amended Pub. L. 115–141, div. U, title II, § 206(i), Mar. 23, 2018, 132 Stat. 1180.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6233, added Pub. L. 98–369, div. A, title VII, § 714(p)(1), July 18, 1984, 98 Stat. 964; amended Pub. L. 104–188, title I, § 1307(c)(3)(B), Aug. 20, 1996, 110 Stat. 1782, related to extension to entities filing partnership returns, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (c). Pub. L. 115–141 added subsec. (c).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DateSection 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.

legal/us/code/title-26/chapter-63/section-6234.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6234"
+description: "Judicial review of partnership adjustment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6234"
+citation: "26 U.S.C. § 6234"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6234"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "98173bb3d4b7dbc3568ccdc276d01f4fe4bcd752547a94e15e362dbb64a6839f"
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+text_hash: "efc6c1158ca4d151fd9b1c5e9d3ae1f19c47e14c12540179fe412c9bcd49585c"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6234 - Judicial review of partnership adjustment
+
+## Text
+
+(a) In general Within 90 days after the date on which a notice of a final partnership adjustment is mailed under section 6231 with respect to any partnership taxable year, the partnership may file a petition for a readjustment for such taxable year with—
+
+(1) the Tax Court,
+
+(2) the district court of the United States for the district in which the partnership’s principal place of business is located, or
+
+(3) the Court of Federal Claims.
+
+(b) Jurisdictional requirement for bringing action in district court or Court of Federal Claims (1) In general A readjustment petition under this section may be filed in a district court of the United States or the Court of Federal Claims only if the partnership filing the petition deposits with the Secretary, on or before the date the petition is filed, the amount of (as of the date of the filing of the petition) the imputed underpayment, penalties, additions to tax, and additional amounts with respect to such imputed underpayment if the partnership adjustment was made as provided by the notice of final partnership adjustment. The court may by order provide that the jurisdictional requirements of this paragraph are satisfied where there has been a good faith attempt to satisfy such requirement and any shortfall of the amount required to be deposited is timely corrected.
+
+(2) Interest payable Any amount deposited under paragraph (1), while deposited, shall not be treated as a payment of tax for purposes of this title (other than chapter 67).
+
+(c) Scope of judicial review A court with which a petition is filed in accordance with this section shall have jurisdiction to determine all partnership-related items for the partnership taxable year to which the notice of final partnership adjustment relates, the proper allocation of such items among the partners, and the applicability of any penalty, addition to tax, or additional amount for which the partnership may be liable under this subchapter.
+
+(d) Determination of court reviewable Any determination by a court under this section shall have the force and effect of a decision of the Tax Court or a final judgment or decree of the district court or the Court of Federal Claims, as the case may be, and shall be reviewable as such. The date of any such determination shall be treated as being the date of the court’s order entering the decision.
+
+(e) Effect of decision dismissing action If an action brought under this section is dismissed other than by reason of a rescission under section 6231(c),11 See References in Text note below. the decision of the court dismissing the action shall be considered as its decision that the notice of final partnership adjustment is correct, and an appropriate order shall be entered in the records of the court.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 634; amended Pub. L. 114–113, div. Q, title IV, § 411(b)(2), (3), Dec. 18, 2015, 129 Stat. 3122; Pub. L. 115–141, div. U, title II, §§ 201(c)(7), 206(j), Mar. 23, 2018, 132 Stat. 1173, 1180.)
+
+## Notes
+
+Editorial Notes
+
+References in TextSection 6231(c), referred to in subsec. (e), was redesignated section 6231(d) by Pub. L. 115–141, div. U, title II, § 206(h)(1), Mar. 23, 2018, 132 Stat. 1179.
+
+Prior ProvisionsA prior section 6234, added Pub. L. 105–34, title XII, § 1231(a), Aug. 5, 1997, 111 Stat. 1020; amended Pub. L. 107–147, title IV, § 416(d)(1)(D), Mar. 9, 2002, 116 Stat. 55, related to declaratory judgment relating to treatment of items other than partnership items with respect to an oversheltered return, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
+
+Amendments2018—Subsec. (b)(1). Pub. L. 115–141, § 206(j), substituted “the amount of (as of the date of the filing of the petition) the imputed underpayment, penalties, additions to tax, and additional amounts with respect to such imputed underpayment” for “the amount of the imputed underpayment (as of the date of the filing of the petition)”. Subsec. (c). Pub. L. 115–141, § 201(c)(7), substituted “all partnership-related items” for “all items of income, gain, loss, deduction, or credit of the partnership”. 2015—Pub. L. 114–113 substituted “Court of Federal Claims” for “Claims Court” wherever appearing.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 of 2015 AmendmentAmendment by Pub. L. 114–113 effective as if included in section 1101 of Pub. L. 114–74, see section 411(e) of Pub. L. 114–113, set out as a note under section 6031 of this title.
+
+Effective DateSection 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.

legal/us/code/title-26/chapter-63/section-6235.md

@@ -0,0 +1,75 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6235"
+description: "Period of limitations on making adjustments"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6235"
+citation: "26 U.S.C. § 6235"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6235"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "e568a4ce3660a0af0ab2c1772a62026eb99ed5872030093b45427bea669a022d"
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+text_hash: "cc039a26832c0824a307e55f31985a1a0c25f5beb0800a114b9696ca3eb1a6c7"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6235 - Period of limitations on making adjustments
+
+## Text
+
+(a) In general Except as otherwise provided in this section or section 905(c), no adjustment under this subchapter for any partnership taxable year may be made after the later of—
+
+(1) the date which is 3 years after the latest of—
+
+(A) the date on which the partnership return for such taxable year was filed,
+
+(B) the return due date for the taxable year, or
+
+(C) the date on which the partnership filed an administrative adjustment request with respect to such year under section 6227, or
+
+(2) in the case of any modification of an imputed underpayment under section 6225(c), the date that is 270 days (plus the number of days of any extension consented to by the Secretary under paragraph (7) thereof) after the date on which everything required to be submitted to the Secretary pursuant to such section is so submitted, or
+
+(3) in the case of any notice of a proposed partnership adjustment under section 6231(a)(2), the date that is 330 days (plus the number of days of any extension consented to by the Secretary under section 6225(c)(7)) after the date of such notice.
+
+(b) Extension by agreement The period described in subsection (a) (including an extension period under this subsection) may be extended by an agreement entered into by the Secretary and the partnership before the expiration of such period.
+
+(c) Special rule in case of fraud, etc. (1) False return In the case of a false or fraudulent partnership return with intent to evade tax, the adjustment may be made at any time.
+
+(2) Substantial omission of income If any partnership omits from gross income an amount properly includible therein and such amount is described in subparagraph (A) or (C) of section 6501(e)(1), subsection (a) shall be applied by substituting “6 years” for “3 years”.
+
+(3) No return In the case of a failure by a partnership to file a return for any taxable year, the adjustment may be made at any time.
+
+(4) Return filed by Secretary For purposes of this section, a return executed by the Secretary under subsection (b) of section 6020 on behalf of the partnership shall not be treated as a return of the partnership.
+
+(5) Information required to be reported In the case of a partnership that is required to report any information described in section 6501(c)(8), the time for making any adjustment under this subchapter with respect to any tax return, event, or period to which such information relates shall not expire before the date that is determined under section 6501(c)(8).
+
+(6) Listed transactions If a partnership fails to include on any return or statement any information with respect to a listed transaction as described in section 6501(c)(10), the time for making any adjustment under this subchapter with respect to such transaction shall not expire before the date that is determined under section 6501(c)(10).
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 635; amended Pub. L. 114–113, div. Q, title IV, § 411(c), Dec. 18, 2015, 129 Stat. 3122; Pub. L. 115–141, div. U, title II, § 206(k), Mar. 23, 2018, 132 Stat. 1180.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2018—Subsec. (a). Pub. L. 115–141, § 206(k)(1), inserted “or section 905(c)” after “Except as otherwise provided in this section” and substituted “subchapter” for “subpart” in introductory provisions. Subsec. (a)(3). Pub. L. 115–141, § 206(k)(2), substituted “section 6225(c)(7))” for “section 6225(c)(7)”. Subsec. (c)(2). Pub. L. 115–141, § 206(k)(3), substituted “subparagraph (A) or (C) of section 6501(e)(1)” for “section 6501(e)(1)(A)”. Subsec. (c)(5), (6). Pub. L. 115–141, § 206(k)(4), added pars. (5) and (6). Subsec. (d). Pub. L. 115–141, § 206(k)(5), struck out subsec. (d). Text read as follows: “If notice of a final partnership adjustment with respect to any taxable year is mailed under section 6231, the running of the period specified in subsection (a) (as modified by the other provisions of this section) shall be suspended— “(1) for the period during which an action may be brought under section 6234 (and, if a petition is filed under such section with respect to such notice, until the decision of the court becomes final), and “(2) for 1 year thereafter.” 2015—Subsec. (a)(2). Pub. L. 114–113, § 411(c)(1), substituted “paragraph (7)” for “paragraph (4)”. Subsec. (a)(3). Pub. L. 114–113, § 411(c)(2), substituted “330 days (plus the number of days of any extension consented to by the Secretary under section 6225(c)(7)” for “270 days”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 of 2015 AmendmentAmendment by Pub. L. 114–113 effective as if included in section 1101 of Pub. L. 114–74, see section 411(e) of Pub. L. 114–113, set out as a note under section 6031 of this title.
+
+Effective DateSection 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.

legal/us/code/title-26/chapter-63/section-6241.md

@@ -0,0 +1,117 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 6241"
+description: "Definitions and special rules"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "63"
+chapter_name: "ASSESSMENT"
+section: "6241"
+citation: "26 U.S.C. § 6241"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s6241"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "5deeb5293bf959c0a01dea7c7d059b5ebbb80f34c35d2438adbad5afa2cd8e81"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "303d33fe46bf49913fb4db8236abee61cff3247e142088f615bf1a974ed009ff"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 6241 - Definitions and special rules
+
+## Text
+
+For purposes of this subchapter—
+
+(1) Partnership The term “partnership” means any partnership required to file a return under section 6031(a).
+
+(2) Partnership adjustment (A) In general The term “partnership adjustment” means any adjustment to a partnership-related item.
+
+(B) Partnership-related item The term “partnership-related item” means—
+
+(i) any item or amount with respect to the partnership (without regard to whether or not such item or amount appears on the partnership’s return and including an imputed underpayment and any item or amount relating to any transaction with, basis in, or liability of, the partnership) which is relevant (determined without regard to this subchapter) in determining the tax liability of any person under chapter 1, and
+
+(ii) any partner’s distributive share of any item or amount described in clause (i).
+
+(3) Return due date The term “return due date” means, with respect to the taxable year, the date prescribed for filing the partnership return for such taxable year (determined without regard to extensions).
+
+(4) Payments nondeductible No deduction shall be allowed under subtitle A for any payment required to be made by a partnership under this subchapter.
+
+(5) Partnerships having principal place of business outside United States For purposes of section 6234, a principal place of business located outside the United States shall be treated as located in the District of Columbia.
+
+(6) Partnerships in cases under title 11 of United States Code (A) Suspension of period of limitations on making adjustment, assessment, or collection The running of any period of limitations provided in this subchapter on making a partnership adjustment (or provided by section 6501 or 6502 on the assessment or collection of any imputed underpayment determined under this subchapter) shall, in a case under title 11 of the United States Code, be suspended during the period during which the Secretary is prohibited by reason of such case from making the adjustment (or assessment or collection) and—
+
+(i) for adjustment or assessment, 60 days thereafter, and
+
+(ii) for collection, 6 months thereafter.
+
+A rule similar to the rule of section 6213(f)(2) shall apply for purposes of section 6232(b).
+
+(B) Suspension of period of limitation for filing for judicial review The running of the period specified in section 6234 shall, in a case under title 11 of the United States Code, be suspended during the period during which the partnership is prohibited by reason of such case from filing a petition under section 6234 and for 60 days thereafter.
+
+(7) Treatment where partnership ceases to exist If a partnership ceases to exist before a partnership adjustment under this subchapter takes effect, such adjustment shall be taken into account by the former partners of such partnership under regulations prescribed by the Secretary.
+
+(8) Extension to entities filing partnership return If a partnership return is filed by an entity for a taxable year but it is determined that the entity is not a partnership (or that there is no entity) for such year, then, to the extent provided in regulations, the provisions of this subchapter are hereby extended in respect of such year to such entity and its items and to persons holding an interest in such entity.
+
+(9) Coordination with other chapters (A) In general This subchapter shall not apply with respect to any tax imposed (including any amount required to be deducted or withheld) under chapter 2, 2A, 3, or 4, except that any partnership adjustment determined under this subchapter for purposes of chapter 1 shall be taken into account for purposes of determining any such tax to the extent that such adjustment is relevant to such determination.
+
+(B) Timing of withholding In the case of any tax imposed (including any amount required to be deducted or withheld) under chapter 3 or 4, which is determined with respect to an adjustment described in subparagraph (A), such tax—
+
+(i) shall be so determined with respect to the reviewed year, and
+
+(ii) shall be so imposed (or so required to be deducted or withheld) with respect to the adjustment year.
+
+(C) Statute of limitation on assessment For special rule with respect to limitation on assessment of taxes under chapter 2 or 2A which are attributable to any partnership adjustment, see section 6501(c)(12).
+
+(10) Authority to require electronic filing 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.
+
+(11) Treatment of special enforcement matters (A) In general In the case of partnership-related items which involve special enforcement matters, the Secretary may prescribe regulations pursuant to which—
+
+(i) this subchapter (or any portion thereof) does not apply to such items, and
+
+(ii) such items are subject to such special rules (including rules related to assessment and collection) as the Secretary determines to be necessary for the effective and efficient enforcement of this title.
+
+(B) Special enforcement matters For purposes of subparagraph (A), the term “special enforcement matters” means—
+
+(i) failure to comply with the requirements of section 6226(b)(4)(A)(ii),
+
+(ii) assessments under section 6851 (relating to termination assessments of income tax) or section 6861 (relating to jeopardy assessments of income, estate, gift, and certain excise taxes),
+
+(iii) criminal investigations,
+
+(iv) indirect methods of proof of income,
+
+(v) foreign partners or partnerships, and
+
+(vi) other matters that the Secretary determines by regulation present special enforcement considerations.
+
+(12) United States shareholders and certain other persons treated as partners (A) In general Except as otherwise provided by the Secretary, in the case of any controlled foreign corporation (as defined in section 957 or 953(c)(1)) which is a partner of a partnership, each United States shareholder (as defined in section 951(b) or 953(c)(1)) with respect to such controlled foreign corporation shall be treated for purposes of this subchapter as a partner of such partnership. For purposes of the preceding sentence, any distributive share of any such United States shareholder with respect to such partnership shall, except as otherwise provided by the Secretary, be equal to such United States shareholder’s pro rata share with respect to such controlled foreign corporation (determined under rules similar to the rules of section 951(a)(2)).
+
+(B) Passive foreign investment companies For purposes of subparagraph (A), in the case of a passive foreign investment company (as defined in section 1297), each taxpayer that makes an election under section 1295 with respect to such company shall be treated in the same manner as United States shareholders under subparagraph (A), except that such taxpayer’s pro rata share with respect to the passive foreign investment company shall be determined under rules similar to the rules of section 1293(b).
+
+(C) Regulations or other guidance The Secretary shall issue such regulations or other guidance as is necessary or appropriate to carry out the purposes of this paragraph, including regulations which apply the rules of subparagraph (A) in similar circumstances or with respect to similarly situated persons.
+
+(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 636; amended Pub. L. 115–141, div. U, title II, §§ 201(a), (b)(1), 206(c), (l), (m), (p)(7), Mar. 23, 2018, 132 Stat. 1171, 1172, 1178, 1180–1182.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 6241, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 100, related to consistency of a partner’s return with the partnership return, prior to repeal by Pub. L. 114–74, title XI, § 1101(b)(2), (g), Nov. 2, 2015, 129 Stat. 625, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017. Another prior section 6241, added Pub. L. 97–354, § 4(a), Oct. 19, 1982, 96 Stat. 1691, directed that tax treatment be determined at the corporate level, prior to repeal by Pub. L. 104–188, title I, §§ 1307(c)(1), 1317(a), Aug. 20, 1996, 110 Stat. 1781, 1787, applicable to taxable years beginning after Dec. 31, 1996. A prior section 6242, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1010, related to procedures for taking partnership adjustments into account, prior to repeal by Pub. L. 114–74, title XI, § 1101(b)(2), (g), Nov. 2, 2015, 129 Stat. 625, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017. Another prior section 6242, added Pub. L. 97–354, § 4(a), Oct. 19, 1982, 96 Stat. 1691, directed that shareholder’s return be consistent with corporate return, prior to repeal by Pub. L. 104–188, title I, §§ 1307(c)(1), 1317(a), Aug. 20, 1996, 110 Stat. 1781, 1787, applicable to taxable years beginning after Dec. 31, 1996. A prior section 6243, added Pub. L. 97–354, § 4(a), Oct. 19, 1982, 96 Stat. 1691, directed that shareholders be notified of proceedings and given opportunity to participate, prior to repeal by Pub. L. 104–188, title I, §§ 1307(c)(1), 1317(a), Aug. 20, 1996, 110 Stat. 1781, 1787, applicable to taxable years beginning after Dec. 31, 1996. A prior section 6244, added Pub. L. 97–354, § 4(a), Oct. 19, 1982, 96 Stat. 1691, directed that certain provisions of subchapter C apply to subchapter S items, prior to repeal by Pub. L. 104–188, title I, §§ 1307(c)(1), 1317(a), Aug. 20, 1996, 110 Stat. 1781, 1787, applicable to taxable years beginning after Dec. 31, 1996. A prior section 6245, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1013, authorized and directed Secretary to make necessary partnership adjustment, prior to repeal by Pub. L. 114–74, title XI, § 1101(b)(2), (g), Nov. 2, 2015, 129 Stat. 625, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017. Another prior section 6245, added Pub. L. 97–354, § 4(a), Oct. 19, 1982, 96 Stat. 1692, defined “subchapter S item” for purposes of subchapter, prior to repeal by Pub. L. 104–188, title I, §§ 1307(c)(1), 1317(a), Aug. 20, 1996, 110 Stat. 1781, 1787, applicable to taxable years beginning after Dec. 31, 1996. Prior sections 6246 to 6255 were repealed by Pub. L. 114–74, title XI, § 1101(b)(2), (g), Nov. 2, 2015, 129 Stat. 625, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017. Section 6246, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1013, related to restrictions on partnership adjustments. Section 6247, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1014, related to judicial review of partnership adjustment. Section 6248, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1015, related to period of limitations for making adjustments under this subpart. Section 6251, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1016, related to administrative adjustment requests. Section 6252, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1016, related to judicial review where administrative adjustment request is not allowed in full. Section 6255, added Pub. L. 105–34, title XII, § 1222(a), Aug. 5, 1997, 111 Stat. 1017, defined terms for former subchapter D and listed special rules.
+
+Amendments2018—Par. (2). Pub. L. 115–141, § 201(a), amended par. (2) generally. Prior to amendment, text read as follows: “The term ‘partnership adjustment’ means any adjustment in the amount of any item of income, gain, loss, deduction, or credit of a partnership, or any partner’s distributive share thereof.” Par. (5). Pub. L. 115–141, § 206(p)(7), substituted “section 6234” for “sections 6234”. Par. (9). Pub. L. 115–141, § 201(b)(1), added par. (9). Par. (10). Pub. L. 115–141, § 206(c), added par. (10). Par. (11). Pub. L. 115–141, § 206(l), added par. (11). Par. (12). Pub. L. 115–141, § 206(m), added par. (12).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2018 AmendmentAmendment 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 DateSection 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.