26 CFR § 301.6222-1. Partner's return must be consistent with partnership return. 26 U.S. Code § 6225. Partnership adjustment by Secretary 26 U.S. Code § 6226. Alternative to payment of imputed underpayment by partnership 26 U.S. Code § 6227. Administrative adjustment request by partnership 26 U.S. Code § 6231. Notice of proceedings and adjustment 26 U.S. Code § 6232. Assessment, collection, and payment 26 U.S. Code § 6233. Interest and penalties 26 U.S. Code § 6234. Judicial review of partnership adjustment 26 U.S. Code § 6235. Period of limitations on making adjustments 26 U.S. Code § 6241. Definitions and special rules 26 U.S.C. 6223. Partners bound by actions of partnership 26 U.S.C. Section 6221 26 U.S.C. Section 6222. Partner’s return must be consistent with partnership return Adjustments taken into account by partners Adjustments that do not result in an imputed underpayment Administrative Adjustment Requests BBA Appeals BBA Audits BBA Background BBA Terminology Blog contact Duty of Consistency Fiduciary Duties and Partnership Representative Risks Frequently Asked Questions Groups Imputed Underpayments Jason B. Freeman Matthew Roberts Members Modification of an imputed underpayment Notices open forum Opting In Other Topics Partnership Agreements and the BBA Partnership Representative Partnership Representatives Partnership-related item Penalty Defense Primary Resources Push-Out Elections Reg § 301.6222-1. Partner's return must be consistent with partnership return. Reg § 301.6223-1. Partnership representative. Reg § 301.6223-2. Binding effect of actions of the partnership and partnership representative. Reg § 301.6225-1. Partnership adjustment by the Internal Revenue Service. Reg § 301.6225-2. Modification of imputed underpayment. Reg § 301.6225-3. Treatment of partnership adjustments that do not result in an imputed underpayment. Reg § 301.6226-2. Statements furnished to partners and filed with the IRS. Reg § 301.6227-1. Administrative adjustment request by partnership. Reg § 301.6227-2. Determining and accounting for adjustments requested in an administrative adjustment request by the partnership. Reg § 301.6227-3. Adjustments requested in an administrative adjustment request taken into account by reviewed year partners. Reg § 301.6231-1. Notice of proceedings and adjustments. Reg § 301.6232-1. Assessment, collection, and payment of imputed underpayment. Reg § 301.6234-1. Judicial review of partnership adjustment. Reg § 301.6235-1. Period of limitations on making adjustments. Reg § 301.6241-1. Definitions. Reg § 301.6241-3. Treatment where a partnership ceases to exist. Reg § 301.6241-4. Payments nondeductible. Reg § 301.6241-5. Extension to entities filing partnership returns. Reg § 301.6241-6. Coordination with other chapters of the Internal Revenue Code. Register Representation Resources Reg § 301.6221-1. Tax treatment determined at partnership level. Reg § 301.6226-1. Election for an alternative to the payment of the imputed underpayment. Reg § 301.6226-3. Adjustments taken into account by partners. Scope of the BBA Regime sign up Statements furnished to partners and filed with the IRS
Freeman Law, PLLC represents partnerships in IRS partnership audits and tax disputes. Our attorneys are versed in every aspect of the BBA’s partnership regime, from audit notices, to push-out elections, to litigation.
Our attorneys frequently review and amend partnership and operating agreements for entities that are classified as partnerships for federal tax purposes. We offer insight and experience with complex partnership provisions and BBA-compliant partnership agreements.
In addition, our attorneys represent partners in fiduciary litigation related to partnership disputes.
For more information, contact Freeman Law, PLLC or an attorney representative:
Freeman Law, PLLC
2595 Dallas Parkway, Suite 420 Frisco, TX 75034
Jason B. Freeman
Matthew L. Roberts
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