Treasury Regulations (26 C.F.R.)
26 CFR § 301.6231(e)-2
Judicial decision not a bar to certain adjustments.
# (a) In general.
A court decision with respect to a partner's income tax liability attributable to nonpartnership items shall not be a bar to further proceedings with respect to that partner's income tax liability if that partner's partnership items become nonpartnership items after the appropriate time to include such nonpartnership items in the earlier court proceeding has passed. Thus, the Internal Revenue Service could issue a later deficiency notice for the same taxable year with respect to that partner or that partner could bring a refund suit with respect to those items that have become nonpartnership items.
# (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)-2T 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(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.
- 301.6311-1 · Payment by check or money order.