26 USC 6235 - Period of limitations on making adjustments

U.S Code last checked for updates: May 18, 2024

§ 6235.

Period of limitations on making adjustments

(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

(c)

Special rule in case of fraud, etc.

(1)

False return

(2)

Substantial omission of income

(3)

No return

(4)

Return filed by Secretary

(5)

Information required to be reported

(6)

Listed transactions

(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.)

cite as: 26 USC 6235