Treasury Regulations (26 C.F.R.)
26 CFR § 301.6231(e)-1
Effect of a determination with respect to a nonpartnership item on the determination of a partnership item.
# (a) In general.
The determination of an item after it has become a nonpartnership item with respect to a partner is not controlling in the determination of that item with respect to other partners. Thus, for example, the determination by a court in a separate proceeding relating to a partner that a certain partnership expenditure was deductible does not bind either the Internal Revenue Service or the other partners in a later partnership or other proceeding.
# (b) Effective date.
This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6231(e)-1T contained in 26 CFR part 1, revised April 1, 2001.
[T.D. 8965, 66 FR 50562, Oct. 4, 2001]
Source: view the official text
In this part (40 sections)
- 301.6230(c)-1 · Claim arising out of erroneous computation, etc.
- 301.6230(e)-1 · Tax matters partner required to furnish names.
- 301.6231-1 · Notice of proceedings and adjustments.
- 301.6231(a)(1)-1 · Exception for small partnerships.
- 301.6231(a)(2)-1 · Persons whose tax liability is determined indirectly…
- 301.6231(a)(3)-1 · Partnership items.
- 301.6231(a)(5)-1 · Definition of affected item.
- 301.6231(a)(6)-1 · Computational adjustments.
- 301.6231(a)(7)-1 · Designation or selection of tax matters partner.
- 301.6231(a)(7)-2 · Designation or selection of tax matters partner for…
- 301.6231(a)(12)-1 · Special rules relating to spouses.
- 301.6231(c)-1 · Special rules for certain applications for tentative…
- 301.6231(c)-2 · Special rules for certain refund claims based on…
- 301.6231(c)-3 · Limitation on applicability of §§ 301.6231(c)-4 through…
- 301.6231(c)-4 · Termination and jeopardy assessment.
- 301.6231(c)-5 · Criminal investigations.
- 301.6231(c)-6 · Indirect method of proof of income.
- 301.6231(c)-7 · Bankruptcy and receivership.
- 301.6231(c)-8 · Prompt assessment.
- 301.6231(d)-1 · Time for determining profits interest of partners for…
- 301.6231(e)-1 · Effect of a determination with respect to a…
- 301.6231(e)-2 · Judicial decision not a bar to certain adjustments.
- 301.6231(f)-1 · Disallowance of losses and credits in certain cases.
- 301.6232-1 · Assessment, collection, and payment of imputed…
- 301.6233-1 · Extension to entities filing partnership returns.
- 301.6233(a)-1 · Interest and penalties determined from reviewed year.
- 301.6233(b)-1 · Interest and penalties with respect to the adjustment…
- 301.6234-1 · Judicial review of partnership adjustment.
- 301.6235-1 · Period of limitations on making adjustments.
- 301.6241-1 · Definitions.
- 301.6241-2 · Bankruptcy of the partnership.
- 301.6241-3 · Treatment where a partnership ceases to exist.
- 301.6241-4 · Payments nondeductible.
- 301.6241-5 · Extension to entities filing partnership returns.
- 301.6241-6 · Coordination with other chapters of the Internal Revenue…
- 301.6241-7 · Treatment of special enforcement matters.
- 301.6301-1 · Collection authority.
- 301.6302-1 · Manner or time of collection of taxes.
- 301.6303-1 · Notice and demand for tax.
- 301.6305-1 · Assessment and collection of certain liability.