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NOTES:


Source

(Added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 663; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(B)–(D), (I), July 18, 1984, 98 Stat. 964, 965; Pub. L. 105–34, title XI, § 1141(b), title XII, §§ 1232(a), 1234 (a), Aug. 5, 1997, 111 Stat. 981, 1023, 1024; Pub. L. 105–206, title III, § 3507(a), July 22, 1998, 112 Stat. 772; Pub. L. 107–147, title IV, §§ 416(d)(1)(C), 417 (19)(C), Mar. 9, 2002, 116 Stat. 55, 57.)

Amendments

2002—Subsec. (b)(1)(C). Pub. L. 107–147, § 416(d)(1)(C), inserted “or the Attorney General (or his delegate)” after “Secretary”.
Subsec. (b)(2)(B)(i). Pub. L. 107–147, § 417(19)(C), substituted “section 6227 (d)” for “section 6227 (c)”.
1998—Subsec. (a)(7). Pub. L. 105–206 inserted at end “The Secretary shall, within 30 days of selecting a tax matters partner under the preceding sentence, notify all partners required to receive notice under section 6223(a) of the name and address of the person selected.”
1997—Subsec. (a)(1)(B)(i). Pub. L. 105–34, § 1234(a), reenacted heading of cl. (i) without change and amended text generally. Prior to amendment, text read as follows: “The term ‘partnership’ shall not include any partnership if—
“(I) such partnership has 10 or fewer partners each of whom is a natural person (other than a nonresident alien) or an estate, and
“(II) each partner’s share of each partnership item is the same as his share of every other item.
For purposes of the preceding sentence, a husband and wife (and their estates) shall be treated as 1 partner.”
Subsec. (f). Pub. L. 105–34, § 1141(b), substituted “deductions, losses, and” for “losses and” in subsec. heading and “deduction, loss, or” for “loss or” in two places in text.
Subsec. (g). Pub. L. 105–34, § 1232(a), added subsec. (g).
1984—Subsec. (a)(9). Pub. L. 98–369, § 714(p)(2)(B), substituted “S corporation” for “electing small business corporation”.
Subsec. (b)(2)(B). Pub. L. 98–369, § 714(p)(2)(I), substituted section “6227(c)” for “6227(b)”.
Subsec. (d)(1)(A). Pub. L. 98–369, § 714(p)(2)(C), amended subpar. (A) generally, substituting “disposed of” and “disposition” for “liquidated, sold, or exchanged” and “liquidation, sale, or exchange”, respectively.
Subsec. (f). Pub. L. 98–369, § 714(p)(2)(D), substituted “such loss or credit” for “such deduction or credit”.

Effective Date of 2002 Amendment

Amendment by section 416(d)(1)(C) of Pub. L. 107–147 applicable with respect to settlement agreements entered into after Mar. 9, 2002, see section 416(d)(2) of Pub. L. 107–147, set out as a note under section 6224 of this title.

Effective Date of 1998 Amendment

Pub. L. 105–206, title III, § 3507(b), July 22, 1998, 112 Stat. 772, provided that: “The amendment made by this section [amending this section] shall apply to selections of tax matters partners made by the Secretary of the Treasury after the date of the enactment of this Act [July 22, 1998].”

Effective Date of 1997 Amendment

Amendment by section 1141(b) of Pub. L. 105–34 applicable to taxable years beginning after Aug. 5, 1997, see section 1141(c) of Pub. L. 105–34, set out as a note under section 6031 of this title.
Section 1232(b) of Pub. L. 105–34 provided that: “The amendment made by this section [amending this section] shall apply to partnership taxable years ending after the date of the enactment of this Act [Aug. 5, 1997].”
Section 1234(b) of Pub. L. 105–34 provided that: “The amendment made by this section [amending this section] shall apply to partnership taxable years ending after the date of the enactment of this Act [Aug. 5, 1997].”

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.

Special Rule for Certain International Satellite Partnerships

Section 406 of Pub. L. 97–248, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “Subchapter C of chapter 63 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] (relating to tax treatment of partnership items), section 6031 of such Code (relating to returns of partnership income), and section 6046A of such Code (relating to returns as to interest in foreign partnerships) shall not apply to the International Telecommunications Satellite Organization, the International Maritime Satellite Organization, and any organization which is a successor of either of such organizations.”


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