Internal Revenue Code · 26 U.S.C.
§ 6231. Notice of proceedings and adjustment
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. § 6231
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 · 401 words · about 2 min to read
- Cross-references
- cites 3; cited by 5 Code sections and 24 other regulations
- Regulations
- 21 issued under this section
Any notice of a proposed partnership adjustment shall not be mailed later than the date determined under section 6235 (determined without regard to paragraphs (2) and (3) of subsection (a) thereof).
Except to the extent that the partnership elects to waive the application of this subparagraph, any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed.
For the period of limitations on making adjustments, see section 6235.
If the Secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section 6234 with respect to such notice, in the absence of a showing of fraud, malfeasance, or misrepresentation of a material fact, the Secretary shall not mail another such notice to such partnership with respect to such taxable year.
The Secretary may, with the consent of the partnership, rescind any notice of a partnership adjustment mailed to such partnership. Any notice so rescinded shall not be treated as a notice of a partnership adjustment for purposes of this subchapter, and the taxpayer shall have no right to bring a proceeding under section 6234 with respect to such notice.
(Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 632; amended Pub. L. 115–141, div. U, title II, §§ 201(c)(6), 206(h), Mar. 23, 2018, 132 Stat. 1173, 1179.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 6231
- § 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.
- § 301.6231(a)(6)-1 Computational adjustments.
- § 301.6231(a)(7)-1 Designation or selection of tax matters partner.
- § 301.6231(a)(7)-2 Designation or selection of tax matters partner for a limited liability company (LLC).
- § 301.6231(a)(12)-1 Special rules relating to spouses.
- § 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.
- § 301.6231(c)-3 Limitation on applicability of §§ 301.6231(c)-4 through 301.6231(c)-8.
- § 301.6231(c)-4 Termination and jeopardy assessment.
- § 301.6231(c)-5 Criminal investigations.
- § 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.
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 3 other sections
- § 6227 Administrative adjustment request by partnership
- § 6235 Period of limitations on making adjustments
- § 6234 Judicial review of partnership adjustment
Cited by 5 Code sections
- § 6225(c)(7) Partnership adjustment by Secretary
- § 6227(c)(2) Administrative adjustment request by partnership
- § 6234(a) Judicial review of partnership adjustment
- § 6235(a)(3) Period of limitations on making adjustments
- § 6501(c)(12)(B) Limitations on assessment and collection
Cited in 24 regulations not issued under it
- § 1.6031(a)-1 Return of partnership income.
- § 301.6221-1 Tax treatment determined 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)-2 Application of consistent reporting and notification rules to indirect partners.
- § 301.6222(b)-2 Effect of notification of inconsistent treatment.
- § 301.6223-1 Partnership representative.
- § 301.6223-2 Binding effect of actions of the partnership and partnership representative.
- § 301.6223(b)-1 Notice group.
- § 301.6223(h)-1 Responsibilities of pass-thru partner.
- § 301.6224(c)-2 Pass-thru partner binds indirect partners.
- § 301.6224(c)-3 Consistent settlements.
- § 301.6225-1 Partnership adjustment by the Internal Revenue Service.
- § 301.6225-2 Modification of imputed underpayment.
- § 301.6226-1 Election for an alternative to the payment of the imputed underpayment.
- § 301.6229(f)-1 Special rule for partial settlement agreements.
- § 301.6232-1 Assessment, collection, and payment of imputed underpayment.
- § 301.6233-1 Extension to entities filing partnership returns.
- § 301.6234-1 Judicial review of partnership adjustment.
- § 301.6235-1 Period of limitations on making adjustments.
- § 301.6241-1 Definitions.
- § 301.6621-3 Higher interest rate payable on large corporate underpayments.
- § 301.6751(b)-1 Supervisory and higher level official approval for penalties.
- § 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 III PROCEDURE
Nearby sections
- § 6231 Notice of proceedings and adjustment
- § 6232 Assessment, collection, and payment
- § 6233 Interest and penalties
- § 6234 Judicial review of partnership adjustment
- § 6235 Period of limitations on making adjustments
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Prior Provisions
A prior section 6231, added Pub. L. 97–248, title IV, § 402(a), Sept. 3, 1982, 96 Stat. 663; amended Pub. L. 98–369, div. A, title VII, § 714(p)(2)(B)–(D), (I), July 18, 1984, 98 Stat. 964, 965; Pub. L. 105–34, title XI, § 1141(b), title XII, §§ 1232(a), 1234(a), Aug. 5, 1997, 111 Stat. 981, 1023, 1024; Pub. L. 105–206, title III, § 3507(a), July 22, 1998, 112 Stat. 772; Pub. L. 107–147, title IV, §§ 416(d)(1)(C), 417(19)(C), Mar. 9, 2002, 116 Stat. 55, 57, defined terms for purposes of this subchapter and listed special rules for partnership items, prior to repeal by Pub. L. 114–74, title XI, § 1101(a), Nov. 2, 2015, 129 Stat. 625.
Amendments
2018—Subsec. (a). Pub. L. 115–141, § 206(h)(2), substituted “Any notice of a final partnership adjustment” for “Any notice of a final partnership adjustment shall not be mailed earlier than 270 days after the date on which the notice of the proposed partnership adjustment is mailed. Such notices” in concluding provisions.
Subsec. (a)(1). Pub. L. 115–141, § 201(c)(6), substituted “any partnership-related item for any partnership taxable year” for “any item of income, gain, loss, deduction, or credit of a partnership for a partnership taxable year”.
Subsecs. (b) to (d). Pub. L. 115–141, § 206(h)(1), added subsec. (b) and redesignated former subsecs. (b) and (c) as (c) and (d), respectively.
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.
Special Rule for Certain International Satellite Partnerships
Pub. L. 97–248, title IV, § 406, Sept. 3, 1982, 96 Stat. 670, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “[Former] Subchapter C of chapter 63 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] (relating to tax treatment of partnership items), section 6031 of such Code (relating to returns of partnership income), and section 6046A of such Code (relating to returns as to interest in foreign partnerships) shall not apply to the International Telecommunications Satellite Organization, the International Maritime Satellite Organization, and any organization which is a successor of either of such organizations.”