Page:United States Statutes at Large Volume 111 Part 1.djvu/1040

 Ill STAT. 1016 PUBLIC LAW 105-34—AUG. 5, 1997 (b) of section 6020 on behalf of the partnership shall not be treated as a return of the partnership. "(d) SUSPENSION WHEN SECRETARY MAILS NOTICE OF ADJUST- MENT.—I f notice of a partnership adjustment with respect to any taxable year is mailed to the partnership, the running of the period specified in subsection (a) (as modified by the other provisions of this section) shall be suspended— "(1) for the period during which an action may be brought under section 6247 (and, if a petition is filed under section 6247 with respect to such notice, until the decision of the court becomes final), and "(2) for 1 year thereafter. "Subpart B—Claims for Adjustments by Partnership "Sec. 6251. Administrative adjustment requests. "Sec. 6252. Judicial review where administrative adjustment request is not allowed in full. "SEC. 6251. ADMINISTRATIVE ADJUSTMENT REQUESTS. "(a) GENERAL RULE. —^A partnership may file a request for an administrative adjustment of partnership items for any partnership taxable year at any time which is— "(1) within 3 years after the later of— "(A) the date on which the partnership return for such year is filed, or "(B) the last day for filing the partnership return for such year (determined without regard to extensions), and "(2) before the mailing to the partnership of a notice of a partnership adjustment with respect to such taxable year. "(b) SECRETARIAL ACTION.—If a partnership files an administrative adjustment request under subsection (a), the Secretary may allow any part of the requested adjustments. "(c) SPECIAL RULE IN CASE OF EXTENSION UNDER SECTION 6248. —If the period described in section 6248(a) is extended pursuant to an agreement under section 6248(b), the period prescribed by subsection (a)(1) shall not expire before the date 6 months after the expiration of the extension under section 6248(b). "SEC. 6252. JUDICIAL REVIEW WHERE ADMINISTRATIVE ADJUSTMENT REQUEST IS NOT ALLOWED IN FULL. "(a) IN GENERAL.—I f any part of an administrative adjustment request filed under section 6251 is not allowed by the Secretary, the partnership may file a petition for an adjustment with respect to the partnership items to which such part of the request relates with— "(1) the Tax Court, "(2) the district court of the United States for the district in which the principal place of business of the partnership is located, or "(3) the Claims Court. "(b) PERIOD FOR FILING PETITION.—A petition may be filed under subsection (a) with respect to partnership items for a partnership taxable year only— "(1) after the expiration of 6 months from the date of filing of the request under section 6251, and

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