26 U.S. Code § 6222 - Partner’s return must be consistent with partnership return or Secretary notified of inconsistency
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(a) In general
A partner shall, on the partner’s return, treat a partnership item in a manner which is consistent with the treatment of such partnership item on the partnership return.
(b) Notification of inconsistent treatment
(1) In general
In the case of any partnership item, if—
(i) the partnership has filed a return but the partner’s treatment on his return is (or may be) inconsistent with the treatment of the item on the partnership return, or
subsection (a) 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 a partnership item if the partner—
(A) demonstrates to the satisfaction of the Secretary that the treatment of the partnership item on the partner’s return is consistent with the treatment of the item on the schedule furnished to the partner by the partnership, and
(c) Effect of failure to notify
In any case—
section 6225 shall not apply to any part of a deficiency attributable to any computational adjustment required to make the treatment of the items by such partner consistent with the treatment of the items on the partnership return.
Source(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.)
1989—Subsec. (d). Pub. L. 101–239substituted “part II of subchapter A of chapter 68” for “section 6653 (a)”.
1986—Subsec. (d). Pub. L. 99–514struck out “intentional or negligent” after “case of a partner’s”.
Effective Date of 1989 Amendment
Amendment by Pub. L. 101–239applicable to returns the due date for which (determined without regard to extensions) is after Dec. 31, 1989, see section 7721(d) ofPub. L. 101–239, set out as a note under section 461 of this title.
Effective Date of 1986 Amendment