TITLE 26. INTERNAL REVENUE CODE § 6221. Determination at partnership level., 26 USCS § 6221

Summary

(a) In general. Any adjustment to a partnership-related item shall be determined, and any tax attributable thereto shall be assessed and collected, and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to any such item shall be determined, at the partnership level, except to the extent otherwise provided in this subchapter [26 USCS §§ 6221 et seq.].

(b) Election out for certain partnerships with 100 or fewer partners, etc.

(1) In general. This subchapter [26 USCS §§ 6221 et seq.] shall not apply with respect to any partnership for any taxable year if—

(A) the partnership elects the application of this subsection for such taxable year,

(B) for such taxable year the partnership is required to furnish 100 or fewer statements under section 6031(b) [26 USCS § 6031(b)] with respect to its partners,

(C) each of the partners of such partnership is an individual, a C corporation, any foreign entity that would be treated as a C corporation were it ...