Title 26, Internal Revenue CodeRelease 119-110
§6227 Administrative Adjustment Request by Partnership
Title 26 › Subtitle F — Procedure and Administration › CHAPTER 63 — ASSESSMENT › Subchapter C — Treatment of Partnerships › PART II — PARTNERSHIP ADJUSTMENTS › § 6227
Summary
Partnerships may ask the IRS to change one or more partnership items for any tax year. The change counts for the year the request is filed and will be handled either under rules like section 6225 or like section 6226; if the change would not create an imputed underpayment, only the 6226-style rules apply. The request must be filed within 3 years after the later of the return’s filing date or the last day to file without extensions, and it cannot be filed after a section 6231 notice is mailed. The Secretary must issue rules to coordinate this with section 905(c).
Full Legal Text
Title 26, §6227
Internal Revenue Code, Source: USLM XML via OLRC
(a)In general
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.
(b)Adjustment
Any such adjustment under subsection (a) shall be determined and taken into account for the partnership taxable year in which the administrative adjustment request is filed—
(1)by the partnership under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof) for the partnership taxable year in which the administrative adjustment request is filed, or
(2)by the partnership and partners under rules similar to the rules of section 6226 (determined without regard to the substitution described in subsection (c)(2)(C) thereof).
In the case of an adjustment that would not result in an imputed underpayment, paragraph (1) shall not apply and paragraph (2) shall apply with appropriate adjustments.
(c)Period of limitations
A partnership may not file such a request more than 3 years after the later of— (1)
(2)the last day for filing the partnership return for such year (determined without regard to extensions).
In no event may a partnership file such a request after a notice of an administrative proceeding with respect to the taxable year is mailed under section 6231.
(d)Coordination with adjustments related to foreign tax credits
The Secretary shall issue regulations or other guidance which provide for the proper coordination of this section and section 905(c).
Legislative History
Notes & Related Subsidiaries
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 AmendmentAmendment 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.
Reference
Citations & Metadata
Citation
26 U.S.C. § 6227
Title 26, Internal Revenue Code
Last Updated
Sep 22, 2026
Release point: 119-110