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NOTES:


Source

(Added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 660; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(A), July 18, 1984, 98 Stat. 964; Pub. L. 99–514, title XVIII, § 1875(d)(2)(A), Oct. 22, 1986, 100 Stat. 2896; Pub. L. 100–647, title I, § 1018(o)(1), Nov. 10, 1988, 102 Stat. 3584; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 105–34, title XII, §§ 1237(a)–(c)(1), 1238(b)(2)–(6), 1239(c)(1), Aug. 5, 1997, 111 Stat. 1025–1028; Pub. L. 105–206, title III, § 3201(e)(2), July 22, 1998, 112 Stat. 740.)

Amendments

1998—Subsec. (c)(5)(A). Pub. L. 105–206 substituted “section 6015” for “section 6013 (e)”.
1997—Subsec. (a)(1). Pub. L. 105–34, § 1237(c)(1), substituted “paragraph (2) or (3)” for “paragraph (2)”.
Subsec. (a)(2)(A)(i). Pub. L. 105–34, § 1238(b)(2), amended cl. (i) generally. Prior to amendment, cl. (i) read as follows: “affected items which require partner level determinations, or”.
Subsec. (a)(3). Pub. L. 105–34, § 1237(a), added par. (3).
Subsec. (a)(3)(A). Pub. L. 105–34, § 1238(b)(3)(A), inserted “(including any liability for any penalties, additions to tax, or additional amounts relating to such adjustment)” after “partnership item”.
Subsec. (a)(3)(B). Pub. L. 105–34, § 1238(b)(3)(B), inserted “(and the applicability of any penalties, additions to tax, or additional amounts)” after “partnership items”.
Subsec. (c)(1)(C). Pub. L. 105–34, § 1238(b)(4), added subpar. (C).
Subsec. (c)(2)(A). Pub. L. 105–34, § 1238(b)(5), inserted “or (C)” after “(1)(A)” in subpar. heading and substituted “subparagraph (A) or (C) of paragraph (1)” for “paragraph (1)(A)” in text.
Subsec. (c)(4). Pub. L. 105–34, § 1238(b)(6), inserted at end “In addition, the determination under the final partnership administrative adjustment or under the decision of the court (whichever is appropriate) concerning the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to a partnership item shall also be conclusive. Notwithstanding the preceding sentence, the partner shall be allowed to assert any partner level defenses that may apply or to challenge the amount of the computational adjustment.”
Subsec. (c)(5). Pub. L. 105–34, § 1237(b), added par. (5).
Subsec. (c)(5)(A). Pub. L. 105–34, § 1238(b)(3)(C), inserted before period at end “(including any liability for any penalties, additions to tax, or additional amounts relating to such adjustment)”.
Subsec. (c)(5)(D). Pub. L. 105–34, § 1238(b)(3)(D), inserted “(and the applicability of any penalties, additions to tax, or additional amounts)” after “partnership items”.
Subsec. (d)(6). Pub. L. 105–34, § 1239(c)(1), struck out “(or an affected item)” after “partnership item”.
1992—Subsec. (g). Pub. L. 102–572 substituted “Court of Federal Claims” for “Claims Court”.
1988—Subsec. (a)(2)(A)(ii). Pub. L. 100–647 inserted “(other than by reason of section 6231 (b)(1)(C))” after “nonpartnership items”.
1986—Subsec. (a). Pub. L. 99–514 substituted “Coordination with deficiency proceedings” for “Normal deficiency proceedings do not apply to computational adjustments” as subsec. heading, and amended text generally. Prior to amendment text read as follows: “Subchapter B of this chapter shall not apply to the assessment or collection of any computational adjustment.”
1984—Subsec. (c)(1)(B). Pub. L. 98–369 struck out “(or erroneously computed the amount of any such credit or refund)” after “section 6228 (a)”.

Effective Date of 1998 Amendment

Amendment by Pub. L. 105–206 applicable to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date, see section 3201(g)(1) of Pub. L. 105–206, set out as a note under section 6015 of this title.

Effective Date of 1997 Amendment

Section 1237(d) of Pub. L. 105–34 provided that: “The amendments made by this section [amending this section and section 6503 of this title] shall take effect as if included in the amendments made by section 402 of the Tax Equity and Fiscal Responsibility Act of 1982 [Pub. L. 97–248].”
Amendment by section 1238 (b)(2)–(6) of Pub. L. 105–34 applicable to partnership taxable years ending after Aug. 5, 1997, see section 1238(c) of Pub. L. 105–34, set out as a note under section 6221 of this title.
Amendment by section 1239(c)(1) of Pub. L. 105–34 applicable to partnership taxable years ending after Aug. 5, 1997, see section 1239(f) of Pub. L. 105–34, set out as a note under section 6225 of this title.

Effective Date of 1992 Amendment

Amendment by Pub. L. 102–572 effective Oct. 29, 1992, see section 911 of Pub. L. 102–572, set out as a note under section 171 of Title 28, Judiciary and Judicial Procedure.

Effective Date of 1988 Amendment

Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.

Effective Date of 1986 Amendment

Section 1875(d)(2)(C) of Pub. L. 99–514 provided that: “The amendments made by this paragraph [amending this section and sections 6213 and 6503 of this title] shall take effect as if included in the Tax Equity and Fiscal Responsibility Act of 1982 [Pub. L. 97–248].”

Effective Date of 1984 Amendment

Amendment by Pub. L. 98–369 effective as if included in the provision of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97–248, to which such amendment relates, see section 715 of Pub. L. 98–369, set out as a note under section 31 of this title.

Plan Amendments Not Required Until January 1, 1989

For provisions directing that if any amendments made by subtitle A or subtitle C of title XI [§§ 1101–1147 and 1171–1177] or title XVIII [§§ 1800–1899A] of Pub. L. 99–514 require an amendment to any plan, such plan amendment shall not be required to be made before the first plan year beginning on or after Jan. 1, 1989, see section 1140 of Pub. L. 99–514, as amended, set out as a note under section 401 of this title.


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