Sec. 6227 Administrative adjustment request by partnership
(a) In general. A partnership may file a request for an administrative adjustment in the amount of one or more partnership-related items for any partnership taxable year.
(b) Adjustment. Any such adjustment under subsection (a) shall be determined and taken into account for the partnership taxable year in which the administrative adjustment request is filed --
(1) by the partnership under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof) for the partnership taxable year in which the administrative adjustment request is filed, or
(2) by the partnership and partners under rules similar to the rules of section 6226 (determined without regard to the substitution described in subsection (c)(2)(C) thereof).
In the case of an adjustment that would not result in an imputed underpayment, paragraph (1) shall not apply and paragraph (2) shall apply with appropriate adjustments.
(c) Period of limitations. A partnership may not file such a request more than 3 years after the later of --
(1) the date on which the partnership return for such year is filed, or
(2) the last day for filing the partnership return for such year (determined without regard to extensions).
In no event may a partnership file such a request after a notice of an administrative proceeding with respect to the taxable year is mailed under section 6231.
(d) Coordination with adjustments related to foreign tax credits. The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
