
From the U.S. Code Online via GPO Access
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[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC6221]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                Subtitle F--Procedure and Administration
 
                         CHAPTER 63--ASSESSMENT
 
            Subchapter C--Tax Treatment of Partnership Items
 
Sec. 6221. Tax treatment determined at partnership level

    Except as otherwise provided in this subchapter, the tax treatment 
of any partnership item (and the applicability of any penalty, addition 
to tax, or additional amount which relates to an adjustment to a 
partnership item) shall be determined at the partnership level.

(Added Pub. L. 97-248, title IV, Sec. 402(a), Sept. 3, 1982, 96 Stat. 
648; amended Pub. L. 105-34, title XII, Sec. 1238(a), Aug. 5, 1997, 111 
Stat. 1026.)


                               Amendments

    1997--Pub. L. 105-34 inserted ``(and the applicability of any 
penalty, addition to tax, or additional amount which relates to an 
adjustment to a partnership item)'' after ``item''.


                    Effective Date of 1997 Amendment

    Section 1238(c) of Pub. L. 105-34 provided that: ``The amendments 
made by this section [amending this section and sections 6226 and 6230 
of this title] shall apply to partnership taxable years ending after the 
date of the enactment of this Act [Aug. 5, 1997].''


                             Effective Date

    Section 407(a) of Pub. L. 97-248, as amended by Pub. L. 99-514, 
Sec. 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
    ``(1) Except as provided in paragraph (2), the amendments made by 
sections 402, 403, and 404 [enacting this subchapter and section 1508 of 
Title 28, Judiciary and Judicial Procedure, amending sections 702, 6031, 
6213, 6216, 6422, 6501, 6504, 6511, 6512, 6515, 7422, 7451, 7456, 7459, 
7482, and 7485 of this title and section 1346 of Title 28, and enacting 
provisions set out as a note under section 6031 of this title] shall 
apply to partnership taxable years beginning after the date of the 
enactment of this Act [Sept. 3, 1982].
    ``(2) Section 6232 of the Internal Revenue Code of 1986 [formerly 
I.R.C. 1954] shall apply to periods after December 31, 1982.
    ``(3) The amendments made by sections 402, 403, and 404 shall apply 
to any partnership taxable year (or in the case of section 6232 of such 
Code, to any period) ending after the date of the enactment of this Act 
[Sept. 3, 1982] if the partnership, each partner, and each indirect 
partner requests such application and the Secretary of the Treasury or 
his delegate consents to such application.''


                               Short Title

    For short title of title IV of Pub. L. 97-248 as the ``Tax Treatment 
of Partnership Items Act of 1982'', see Short Title of 1982 Amendments 
note set out under section 1 of this title.
