Treasury Regulations · 26 CFR
§ 301.6231-1. Notice of proceedings and adjustments.
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
Cite as 26 CFR § 301.6231-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- February 27, 2019 by T.D. 9844
- Issued under
- 26 U.S.C. § 6231
- Length
- 735 words · about 3 min to read
- Cross-references
- cites 5 Code sections and 6 regulations; cited by 6
¶(a) Notices to which this section applies. In the case of any administrative proceeding under subchapter C of chapter 63 of the Internal Revenue Code (subchapter C of chapter 63), including an administrative proceeding with respect to an administrative adjustment request (AAR) filed by a partnership under section 6227, the following notices must be mailed to the partnership and the partnership representative (as described in section 6223 and § 301.6223-1)—
¶(1) Notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any partnership-related item (as defined in § 301.6241-1(a)(6)(ii)) for any partnership taxable year under subchapter C of chapter 63 (notice of administrative proceeding (NAP));
¶(2) Notice of any proposed partnership adjustment resulting from an administrative proceeding under subchapter C of chapter 63 (notice of proposed partnership adjustment (NOPPA)); and
¶(3) Notice of any final partnership adjustment resulting from an administrative proceeding under subchapter C of chapter 63 (notice of final partnership adjustment (FPA)).
¶(b) Time for mailing notices—
¶(1) Notice of proposed partnership adjustment. A NOPPA is timely if it is mailed before the expiration of the period for making adjustments under section 6235(a)(1) (including any extensions under section 6235(b) and any special rules under section 6235(c)).
¶(2) Notice of final partnership adjustment. An FPA may not be mailed earlier than 270 days after the date on which the NOPPA is mailed unless the partnership agrees, in writing, with the Internal Revenue Service (IRS) to waive the 270-day period. See § 301.6225-2(c)(3)(iii) for the effect of a waiver under this paragraph (b)(2) on the 270-period for requesting a modification under section 6225(c). See § 301.6232-1(d)(2) for the rules regarding a waiver of the limitations on assessment under § 301.6232-1(c).
¶(c) Last known address. A notice described in paragraph (a) of this section is sufficient if mailed to the last known address of the partnership representative and the partnership (even if the partnership or partnership representative has terminated its existence).
¶(d) Notice mailed to partnership representative—
¶(1) In general. A notice described in paragraph (a) of this section will be treated as mailed to the partnership representative if the notice is mailed to the partnership representative that is reflected in the IRS records as of the date the letter is mailed.
¶(2) No partnership representative in effect. In any case in which no partnership representative designation is in effect in accordance with § 301.6223-1(f), a notice described in paragraph (a) of this section mailed to “PARTNERSHIP REPRESENTATIVE” at the last known address of the partnership satisfies the requirements of this section.
¶(e) Restrictions on additional FPAs after petition filed. The IRS may mail more than one FPA to any partnership for any partnership taxable year. However, except in the case of fraud, malfeasance, or misrepresentation of a material fact, the IRS may not mail an FPA to a partnership with respect to a partnership taxable year after the partnership has filed a timely petition for readjustment under section 6234 with respect to an FPA issued with respect to such partnership taxable year.
¶(f) Withdrawal of NAP or NOPPA. The IRS may, without consent of the partnership, withdraw any NAP or NOPPA. Except as described in § 301.6223-1(d)(2) and (e)(2), if the IRS withdraws a NAP or NOPPA under this paragraph (f), the NAP or NOPPA is treated as if it were never issued, and the withdrawn NAP or NOPPA has no effect for purposes of subchapter C of chapter 63. For instance, if the IRS withdraws a NAP with respect to a partnership taxable year, the limitation under § 301.6222-1(c)(5) regarding inconsistent treatment, and the prohibition under section 6227(c) on filing an AAR, after the mailing of a NAP no longer applies with respect to such taxable year.
¶(h) Applicability date—
¶(1) In general. Except as provided in paragraph (h)(2) of this section, this section applies to partnership taxable years beginning after December 31, 2017, and ending after August 12, 2018.
¶(2) Election under § 301.9100-22 in effect. This section applies to any partnership taxable year beginning after November 2, 2015, and before January 1, 2018, for which a valid election under § 301.9100-22 is in effect.
[T.D. 9844, 84 FR 6561, Feb. 27, 2019]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 6227 Administrative adjustment request by partnership
- § 6223 Partners bound by actions of partnership
- § 6235 Period of limitations on making adjustments
- § 6225 Partnership adjustment by Secretary
- § 6234 Judicial review of partnership adjustment
Regulations it cites
- § 301.6223-1 Partnership representative.
- § 301.6241-1 Definitions.
- § 301.6225-2 Modification of imputed underpayment.
- § 301.6232-1 Assessment, collection, and payment of imputed underpayment.
- § 301.6222-1 Partner's return must be consistent with partnership return.
- § 301.9100-22 Time, form, and manner of making the election under section 1101(g)(4) of the Bipartisan Budget Act of 2015 for returns filed for partnership taxable years beginning after November 2, 2015 and before January 1, 2018.
Cited by 6 other regulations
- § 301.6223-1 Partnership representative.
- § 301.6223-2 Binding effect of actions of the partnership and partnership representative.
- § 301.6225-2 Modification of imputed underpayment.
- § 301.6227-1 Administrative adjustment request by partnership.
- § 301.6234-1 Judicial review of partnership adjustment.
- § 301.6235-1 Period of limitations on making adjustments.
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. 9844 (84 FR 6561)
Where it sits in 26 CFR
- Subchapter F Procedure and administration
- Part 301 Procedure and administration
- Subpart ECFR01918753cdbe68b Assessment
- In General
Nearby sections
- § 301.6229(f)-1 Special rule for partial settlement agreements.
- § 301.6230(b)-1 Request that correction not be made.
- § 301.6230(c)-1 Claim arising out of erroneous computation, etc.
- § 301.6230(e)-1 Tax matters partner required to furnish names.
- § 301.6231-1 Notice of proceedings and adjustments.
- § 301.6231(a)(1)-1 Exception for small partnerships.
- § 301.6231(a)(2)-1 Persons whose tax liability is determined indirectly by partnership items.
- § 301.6231(a)(3)-1 Partnership items.
- § 301.6231(a)(5)-1 Definition of affected item.