Internal Revenue Code · 26 U.S.C.
§ 6227. Administrative adjustment request by partnership
Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).
Cite as 26 U.S.C. § 6227
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- November 2, 2015 by Pub. L. 114–74
- Last amended
- March 23, 2018 by Pub. L. 115–141
- Amendments
- 1 dated changes in the source credit
- Length
- 4 subsections · 291 words · about 1 min to read
- Cross-references
- cites 4; cited by 6 Code sections and 23 other regulations
- Regulations
- 5 issued under this section
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.
The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 631; amended Pub. L. 115–141, div. U, title II, §§ 201(c)(5), 206(f), (p)(2), (3), Mar. 23, 2018, 132 Stat. 1173, 1179, 1182.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 6227
- § 301.6227-1 Administrative adjustment request by partnership.
- § 301.6227-2 Determining and accounting for adjustments requested in an administrative adjustment request by the partnership.
- § 301.6227-3 Adjustments requested in an administrative adjustment request taken into account by reviewed year partners.
- § 301.6227(c)-1 Administrative adjustment request by the tax matters partner on behalf of the partnership.
- § 301.6227(d)-1 Administrative adjustment request filed on behalf of a partner.
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 4 other sections
- § 6225 Partnership adjustment by Secretary
- § 6226 Alternative to payment of imputed underpayment by partnership
- § 6231 Notice of proceedings and adjustment
- § 905(c) Applicable rules
Cited by 6 Code sections
- § 6225(c)(2)(F)(ii) Partnership adjustment by Secretary
- § 6231(a)(3) Notice of proceedings and adjustment
- § 6232(a)(2) Assessment, collection, and payment
- § 6235(a)(1)(C) Period of limitations on making adjustments
- § 6696(e)(1) Rules applicable with respect to sections 6694, 6695, 6695A, and 6695B
- § 6702(f) Frivolous tax submissions
Cited in 23 regulations not issued under it
- § 1.45Q-1 Credit for Carbon Oxide Sequestration.
- § 1.48D-6 Elective payment election.
- § 1.170A-14 Qualified conservation contributions.
- § 1.245A-9 Other rules and definitions.
- § 1.905-4 Notification of foreign tax redetermination.
- § 1.951A-2 Tested income and tested loss.
- § 1.6417-2 Rules for making elective payment elections.
- § 1.6418-2 Rules for making transfer elections.
- § 1.6418-3 Additional rules for partnerships and S corporations.
- § 1.6664-2 Underpayment.
- § 301.6222-1 Partner's return must be consistent with partnership return.
- § 301.6223-1 Partnership representative.
- § 301.6225-1 Partnership adjustment by the Internal Revenue Service.
- § 301.6226-2 Statements furnished to partners and filed with the IRS.
- § 301.6226-3 Adjustments taken into account by partners.
- § 301.6231-1 Notice of proceedings and adjustments.
- § 301.6231(c)-1 Special rules for certain applications for tentative carryback and refund adjustments based on partnership losses, deductions, or credits.
- § 301.6231(c)-2 Special rules for certain refund claims based on losses, deductions, or credits from abusive tax shelter partnerships.
- § 301.6232-1 Assessment, collection, and payment of imputed underpayment.
- § 301.6233(b)-1 Interest and penalties with respect to the adjustment year return.
- § 301.6235-1 Period of limitations on making adjustments.
- § 301.6241-1 Definitions.
- § 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.
Amendment history
From the source credit and the official notes, newest first.
Where it sits in the Code
- Subtitle F Procedure and Administration
- Chapter 63 ASSESSMENT
- Subchapter C Treatment of Partnerships
- Part II PARTNERSHIP ADJUSTMENTS
Nearby sections
- § 6225 Partnership adjustment by Secretary
- § 6226 Alternative to payment of imputed underpayment by partnership
- § 6227 Administrative adjustment request by partnership
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Prior Provisions
Prior sections 6227 to 6230 were repealed by Pub. L. 114–74, title XI, § 1101(a), (g), Nov. 2, 2015, 129 Stat. 625, 638, applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017.
Section 6227, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 655; amended Pub. L. 105–34, title XII, §§ 1236(a), 1243(a), Aug. 5, 1997, 111 Stat. 1025, 1029; Pub. L. 107–147, title IV, § 417(19)(A), Mar. 9, 2002, 116 Stat. 56, related to administrative adjustment requests.
Section 6228, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 656; amended Pub. L. 97–448, title III, § 306(c)(1)(B), Jan. 12, 1983, 96 Stat. 2406; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 107–147, title IV, § 417(19)(B), Mar. 9, 2002, 116 Stat. 56, related to judicial review where administrative adjustment request is not allowed in full.
Section 6229, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 659; amended Pub. L. 99–514, title XVIII, § 1875(d)(1), Oct. 22, 1986, 100 Stat. 2896; Pub. L. 100–647, title I, § 1018(o)(3), Nov. 10, 1988, 102 Stat. 3585; Pub. L. 105–34, title XII, §§ 1233(a)–(c), 1235(a), Aug. 5, 1997, 111 Stat. 1023, 1024; Pub. L. 107–147, title IV, § 416(d)(1)(B), Mar. 9, 2002, 116 Stat. 55; Pub. L. 111–147, title V, § 513(a)(2)(B), Mar. 18, 2010, 124 Stat. 112, related to period of limitations for making assessments.
Section 6230, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 660; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(A), July 18, 1984, 98 Stat. 964; Pub. L. 99–514, title XVIII, § 1875(d)(2)(A), Oct. 22, 1986, 100 Stat. 2896; Pub. L. 100–647, title I, § 1018(o)(1), Nov. 10, 1988, 102 Stat. 3584; Pub. L. 102–572, title IX, § 902(b)(2), Oct. 29, 1992, 106 Stat. 4516; Pub. L. 105–34, title XII, §§ 1237(a)–(c)(1), 1238(b)(2)–(6), 1239(c)(1), Aug. 5, 1997, 111 Stat. 1025–1028; Pub. L. 105–206, title III, § 3201(e)(2), July 22, 1998, 112 Stat. 740; Pub. L. 110–172, § 11(a)(36), Dec. 29, 2007, 121 Stat. 2487, related to additional administrative provisions.
Amendments
2018—Subsec. (a). Pub. L. 115–141, § 201(c)(5), substituted “partnership-related items” for “items of income, gain, loss, deduction, or credit of the partnership”.
Subsec. (b). Pub. L. 115–141, § 206(p)(2), substituted “is filed” for “is made” in introductory provisions and in par. (1).
Subsec. (b)(1). Pub. L. 115–141, § 206(p)(3), which directed substitution of “paragraphs (2), (7), and (9)” for “paragraphs (2), (6), and (7)”, was executed by making the substitution for “paragraphs (2), (6) and (7)” to reflect the probable intent of Congress.
Subsec. (d). Pub. L. 115–141, § 206(f), added subsec. (d).
Statutory Notes and Related Subsidiaries
Effective Date of 2018 Amendment
Amendment by Pub. L. 115–141 effective as if included in section 1101 of Pub. L. 114–74, see section 207 of Pub. L. 115–141, set out as a note under section 6031 of this title.
Effective Date
Section applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Pub. L. 114–74, set out as a note under section 6221 of this title.