# § 6227. Administrative adjustment request by partnership
**(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—
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.
**(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).
**(c)** **Period of limitations** A partnership may not file such a request more than 3 years after the later of—
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.
**(1)** the date on which the partnership return for such year is filed, or
**(2)** the last day for filing the partnership return for such year (determined without regard to extensions).
**(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).
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**Source Credit**: (Added Pub. L. 114–74, title XI, § 1101(c)(1), Nov. 2, 2015, 129 Stat. 631; amended Pub. L. 115–141, div. U, title II, §§ 201(c)(5), 206(f), (p)(2), (3), Mar. 23, 2018, 132 Stat. 1173, 1179, 1182.)
## Editorial Notes
### Prior Provisions
Prior sections 6227 to 6230 were repealed by , (g), , , 638, applicable to returns filed for partnership taxable years beginning after .
Section 6227, added , , ; amended , §§ 1236(a), 1243(a), , , 1029; , , , related to administrative adjustment requests.
Section 6228, added , , ; amended , , ; , , ; , , , related to judicial review where administrative adjustment request is not allowed in full.
Section 6229, added , , ; amended , , ; ()(3), , ; , §§ 1233(a)–(c), 1235(a), , , 1024; , , ; , , , related to period of limitations for making assessments.
Section 6230, added , , ; amended , , ; , , ; ()(1), , ; , , ; , §§ 1237(a)–(c)(1), 1238(b)(2)–(6), 1239(c)(1), , ; , , ; , , , related to additional administrative provisions.
### Amendments
2018—Subsec. (a). , substituted “partnership-related items” for “items of income, gain, loss, deduction, or credit of the partnership”.
Subsec. (b). , substituted “is filed” for “is made” in introductory provisions and in par. (1).
Subsec. (b)(1). , 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). , added subsec. (d).
## Statutory Notes and Related Subsidiaries
### Effective Date of 2018 Amendment
Amendment by effective as if included in , see , set out as a note under .
### Effective Date
Section applicable to returns filed for partnership taxable years beginning after , with certain exceptions, see , set out as a note under .