§6233 Interest and penalties

Summary

When a partnership has a tax adjustment for a reviewed year, the partnership must pay interest and may owe penalties or other additions to tax. Interest is figured like other tax interest rules in chapter 67. It runs from the day after the reviewed year’s return due date until the adjustment year’s return due date, or until the imputed underpayment (the tax treated as owed because of the adjustment) is paid. Any changes for partnership years between the reviewed year and the adjustment year are taken into account. If the partnership does not pay the imputed underpayment when it is due, it must pay more interest and penalties. The interest is figured as if the imputed underpayment were an underpayment in the adjustment year. Penalties apply as under section 6651(a)(2) and as if the imputed underpayment were an underpayment for part II of subchapter A of chapter 68. Rules that let a partnership deposit money to stop interest are under section 6603.