§6231 Notice of proceedings and adjustment

Summary

The Secretary must mail the partnership and its partnership representative three types of notices: that an administrative proceeding at the partnership level has begun about an adjustment to partnership items or a partner’s share, any proposed partnership adjustment from that proceeding, and any final partnership adjustment from that proceeding. A proposed-adjustment notice must be mailed by the deadline in section 6235 (ignore paragraphs (2) and (3) of section 6235(a) when figuring that deadline). A final-adjustment notice cannot be mailed sooner than 270 days after the proposed notice unless the partnership waives that wait. If the partnership files a petition under section 6234 about a final notice, the Secretary may not send another final notice for that year unless fraud, malfeasance, or a material misrepresentation is shown. With the partnership’s consent, the Secretary may cancel a mailed notice; a cancelled notice is treated as if it was never sent and cannot be challenged under section 6234.