Treasury Regulations · 26 CFR
§ 301.6231(e)-1. Effect of a determination with respect to a nonpartnership item on the determination of a partnership item.
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. § 6231(e)
Cite as 26 CFR § 301.6231(e)-1
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. § 6231(e)
- Length
- 122 words · about 1 min to read
¶(a) In general. The determination of an item after it has become a nonpartnership item with respect to a partner is not controlling in the determination of that item with respect to other partners. Thus, for example, the determination by a court in a separate proceeding relating to a partner that a certain partnership expenditure was deductible does not bind either the Internal Revenue Service or the other partners in a later partnership or other proceeding.
¶(b) Effective date. This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6231(e)-1T contained in 26 CFR part 1, revised April 1, 2001.
[T.D. 8965, 66 FR 50562, Oct. 4, 2001]
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 50562)
Where it sits in 26 CFR
- Subchapter F Procedure and administration
- Part 301 Procedure and administration
- Subpart ECFR01918753cdbe68b Assessment
- In General
Nearby sections
- § 301.6231(c)-6 Indirect method of proof of income.
- § 301.6231(c)-7 Bankruptcy and receivership.
- § 301.6231(c)-8 Prompt assessment.
- § 301.6231(d)-1 Time for determining profits interest of partners for purposes of sections 6223(b) and 6231(a)(11).
- § 301.6231(e)-1 Effect of a determination with respect to a nonpartnership item on the determination of a partnership item.
- § 301.6231(e)-2 Judicial decision not a bar to certain adjustments.
- § 301.6231(f)-1 Disallowance of losses and credits in certain cases.
- § 301.6232-1 Assessment, collection, and payment of imputed underpayment.
- § 301.6233-1 Extension to entities filing partnership returns.