Page:United States Statutes at Large Volume 100 Part 3.djvu/1088

 100 STAT. 2896

PUBLIC LAW 99-514—OCT. 22, 1986 (d) AMENDMENTS RELATING TO SECTION 714 OF THE ACT.— (1) PERIOD OF LIMITATIONS.—Section 6229 is amended by

adding at the end thereof the following new subsection: "(g) PERIOD OF LIMITATIONS FOR PENALTIES.—The provisions of this section shall apply also in the case of any addition to tax or an additional amount imposed under subchapter A of chapter 68 which arises with respect to any tax imposed under subtitle A in the same manner as if such addition or additional amount were a tax imposed by subtitle A." (2) COORDINATION WITH DEFICIENCY PROCEEDINGS.—

(A) IN GENERAL.—Subsection (a) of section 6230 is amended to read as follows: "(a) COORDINATION WITH DEFICIENCY PROCEEDINGS.—

"(1) IN GENERAL.—Except as provided in paragraph (2), subchapter B of this chapter shall not apply to the assessment or ^j J, collection of any computational adjustment. "(2) DEFICIENCY PROCEEDINGS TO APPLY IN CERTAIN CASES.—

"(A) Subchapter B shall apply to any deficiency attributable to— > r;xr "(i) affected items which require partner level determinations, or "(ii) items which have become nonpartnership items and are described in section 6231(e)(l)(B). "(B) Subchapter B shall be applied separately with respnect to each deficiency described in subparagraph (A) attributable to each partnership. "(C) Notwithstanding any other law or rule of law, any notice or proceeding under subchapter B with respect to a deficiency described in this paragraph shall not preclude or be precluded by any other notice, proceeding, or determinaw>ii r tion with respect to a partner's tax liability for a taxable year." (B) TECHNICAL AMENDMENTS.—

(i) Paragraph (4) of section 6213(h) is amended to read as follows:

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"(4) For provisions relating to application of this subchapter in the case of certain partnership items, etc., see section 6230(a)."

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(ii) Paragraph (1) of section 6503(a) is amended by striking out "section 6501 or 6502" and inserting in lieu thereof "section 6501 or 6502 (or section 6229, but only with respect to a deficiency described in section 6230(a)(2)(A))." '5. i (C) EFFECTIVE DATE.—The amendments made by this paragraph shall take effect as if included in the Tax Equity and Fiscal Responsibility Act of 1982. (3) EFFECTIVE DATE PROVISION.—Notwithstanding section 715 of the Tax Reform Act of 1984, the amendments made by section 714(n)(2) of such Act shall apply only to applications filed after July 18, 1984. (3) ESTATE AND TRUST INTERESTS HELD BY NOMINEES.—

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(A) IN GENERAL.—Section 6034A is amended— (i) by striking out "The fiduciary" and inserting in lieu thereof "(a) GENERAL RULE.—The fiduciary", (ii) by striking out "each beneficiary" and inserting in lieu thereof '^ach beneficiary (or nominee thereof)',

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