Effect of election
(b) Effect of election(1) Reviewed year partners. If a partnership makes a valid election under this section with respect to any imputed underpayment, the reviewed year partners (as defined in 301.6241-1(a)(9)) must take into account their share of the partnership adjustments (as defined in 301.6241-1(a)(6)) that are associated with that imputed underpayment and are liable for any tax, penalties, additions to tax, additional amounts, and interest as described in 301.6226-3. See 301.6226-2(f) regarding the determination of each reviewed year partner's share of the partnership adjustments, including the effect of any modification approved by the Internal Revenue Service (IRS) under 301.6225-2. (2) Partnership. A partnership making a valid election under this section is not liable for the imputed underpayment to which the election applies (and no assessment of tax, levy, or proceeding in any court for the collection of such imputed underpayment may be made against such partnership). Any adjustments that do not result in an imputed underpayment described in 301.6225-1(f) that are associated with an imputed underpayment (as described in 301.6225-1(g)) for which an election under this section is made are not taken into account by the partnership in the adjustment year (as defined in 301.6241-1(a)(1)) and instead each reviewed year partners' share of the adjustments determined in accordance with 301.6226-2(f) must be included on the statement described in 301.6226-2.