The term “electing large partnership” has the meaning given to such term by section
(2) Partnership item
The term “partnership item” has the meaning given to such term by section
(b) Partners bound by actions of partnership, etc.
(1) Designation of partner
Each electing large partnership shall designate (in the manner prescribed by the Secretary) a partner (or other person) who shall have the sole authority to act on behalf of such partnership under this subchapter. In any case in which such a designation is not in effect, the Secretary may select any partner as the partner with such authority.
(2) Binding effect
An electing large partnership and all partners of such partnership shall be bound—
(A)by actions taken under this subchapter by the partnership, and
(B)by any decision in a proceeding brought under this subchapter.
(c) Partnerships having principal place of business outside the United States
For purposes of sections
6252, a principal place of business located outside the United States shall be treated as located in the District of Columbia.
(d) 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.
(e) Date decision becomes final
For purposes of this subchapter, the principles of section
7481(a) shall be applied in determining the date on which a decision of a district court or the Claims Court becomes final.
(f) Partnerships in cases under title 11 of the United States Code
(1) 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
6502 on the assessment or collection of any amount required to be paid under section
6242) 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—
(A)for adjustment or assessment, 60 days thereafter, and
(B)for collection, 6 months thereafter.
A rule similar to the rule of section
6213(f)(2) shall apply for purposes of section
(2) Suspension of period of limitation for filing for judicial review
The running of the period specified in section
6252(b) 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
6252 and for 60 days thereafter.
The Secretary shall prescribe such regulations as may be necessary to carry out the provisions of this subchapter, including regulations—
(1)to prevent abuse through manipulation of the provisions of this subchapter, and
(2)providing that this subchapter shall not apply to any case described in section
6231(c)(1) (or the regulations prescribed thereunder) where the application of this subchapter to such a case would interfere with the effective and efficient enforcement of this title.
In any case to which this subchapter does not apply by reason of paragraph (2), rules similar to the rules of sections
6255(f) shall apply.
The table below lists the classification updates, since Jan. 3, 2012, for this section. Updates to a broader range of sections may be found at the update page for containing chapter, title, etc.
The most recent Classification Table update that we have noticed was Tuesday, August 13, 2013
An empty table indicates that we see no relevant changes listed in the classification tables. If you suspect that our system may be missing something, please double-check with the Office of the Law Revision Counsel.
Description of Change
Statutes at Large
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