Treasury Regulations · 26 CFR
§ 301.6222(a)-2. Application of consistent reporting and notification rules to indirect partners.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 6222(a)
Cite as 26 CFR § 301.6222(a)-2
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- October 4, 2001 by T.D. 8965
- Issued under
- 26 U.S.C. § 6222(a)
- Length
- 884 words · about 4 min to read
- Defines
- 1 term
- Cross-references
- cites 2 Code sections and 2 regulations; cited by 1
One of the partners in Partnership A is Partnership B, which has four equal partners C, D, E, and F. Both A and B are partnerships within the meaning of section 6231(a)(1). On its return, A reports $100,000 as B's distributive share of A's ordinary income. B, however, reports only $80,000 as its distributive share of the income and does not notify the Internal Revenue Service of this inconsistent treatment with respect to A. C reports $20,000 as its distributive share of the item. Although C reports the item consistently with B, C is subject to a computational adjustment to conform the treatment of that item on C's return to the treatment of that item on A's return.
Assume the same facts as in Example 1, except that B notified the Internal Revenue Service of its inconsistent treatment with respect to source partnership A. C is not subject to a computational adjustment.
Assume the same facts as in Example 1. D reports only $15,000 as D's distributive share of the income and does not report the inconsistency. F reports only $9,000 as its distributive share of the item but reports this inconsistency with respect to source partnership A. D is subject to a computational adjustment to conform the treatment of that item on D's return to the treatment of that item on A's return. F is not subject to a computational adjustment.
Assume the same facts as in Example 3, except that F reported the inconsistency with respect to B and did not report the inconsistency with respect to source partnership A. F is subject to a computational adjustment to conform the treatment of that item on F's return to the treatment of that item on A's return.
Assume the same facts as in Example 1. E reports $25,000 as its distributive share of the item. Regardless of whether E reports the inconsistency between its treatment of the item and that by B, E is neither subject to a computational adjustment to conform E's treatment of that item to that of B nor subject to the notice described in section 6231(b)(1)(A) with respect to any such notification of inconsistent treatment.
[T.D. 8965, 66 FR 50545, Oct. 4, 2001]
Terms defined here
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Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 6231 Notice of proceedings and adjustment
- § 6222 Partner’s return must be consistent with partnership return
Regulations it cites
- § 301.6222(a)-1 Consistent treatment of partnership items.
- § 301.6222(b)-1 Notification to the Internal Revenue Service when partnership items are treated inconsistently.
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 8965 (66 FR 50545)
Where it sits in 26 CFR
- Subchapter F Procedure and administration
- Part 301 Procedure and administration
- Subpart ECFR01918753cdbe68b Assessment
- In General
Nearby sections
- § 301.6221(a)-1 Determination at partnership level.
- § 301.6221(b)-1 Election out for certain partnerships with 100 or fewer partners.
- § 301.6222-1 Partner's return must be consistent with partnership return.
- § 301.6222(a)-1 Consistent treatment of partnership items.
- § 301.6222(a)-2 Application of consistent reporting and notification rules to indirect partners.
- § 301.6222(b)-1 Notification to the Internal Revenue Service when partnership items are treated inconsistently.
- § 301.6222(b)-2 Effect of notification of inconsistent treatment.
- § 301.6222(b)-3 Partner receiving incorrect schedule.
- § 301.6223-1 Partnership representative.