Except as otherwise provided in this subchapter, the tax treatment of any partnership item (and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to a partnership item) shall be determined at the partnership level.
Except as otherwise provided in this subchapter, the tax treatment of any partnership item (and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to a partnership item) shall be determined at the partnership level.
1997—Pub. L. 105–34inserted “(and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to a partnership item)” after “item”.
Effective Date of 1997 Amendment
Section 1238(c) ofPub. L. 105–34provided that: “The amendments made by this section [amending this section and sections
6226 and
6230 of this title] shall apply to partnership taxable years ending after the date of the enactment of this Act [Aug. 5, 1997].”
“(1) Except as provided in paragraph (2), the amendments made by sections
402,
403, and
404 [enacting this subchapter and section
1508 of Title
28, Judiciary and Judicial Procedure, amending sections
702,
6031,
6213,
6216,
6422,
6501,
6504,
6511,
6512,
6515,
7422,
7451,
7456,
7459,
7482, and
7485 of this title and section
1346 of Title
28, and enacting provisions set out as a note under section
6031 of this title] shall apply to partnership taxable years beginning after the date of the enactment of this Act [Sept. 3, 1982].
“(2) Section 6232 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] shall apply to periods after December 31, 1982.
“(3) The amendments made by sections
402,
403, and
404 shall apply to any partnership taxable year (or in the case of section 6232 of such Code, to any period) ending after the date of the enactment of this Act [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.”
Short Title
For short title of title IV of Pub. L. 97–248as the “Tax Treatment of Partnership Items Act of 1982”, see Short Title of 1982 Amendments note set out under section
1 of this title.
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26 USC
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