Page:United States Statutes at Large Volume 96 Part 1.djvu/711

 PUBLIC LAW 97-248—SEPT. 3, 1982

96 STAT. 669

filed, and with surety approved by the Tax Court, conditioned upon the payment of deficiencies attributable to the partnership items to which that decision relates as finally determined, together with any interest, additional amounts, or additions to the tax provided by law. Unless otherwise stipulated by the parties, the amount fixed by the Tax Court shall be based upon its estimate of the aggregate of such deficiencies." (17) Subsection (e) of section 1346 of title 28, United States Code (relating to jurisdiction of district courts with the United States as defendant) is amended by striking out "section 7426 or section" and inserting in lieu thereof "section 6226, 6228(a), 7426, or". (18)(A) Chapter 91 of title 28, United States Code (relating to Claims Court), is amended by adding at the end thereof the following new section: "§ 1508. Jurisdiction for certain partnership proceedings 28 USC 1508. "The Claims Court shall have jurisdiction to hear and to render judgment upon any petition under section 6226 or 6228(a) of the Internal Revenue Code of 1954." Ante, pp. 653, (B) The section analysis of chapter 91 of title 28, United States ^^^• Code (relating to Claims Court) is amended by adding at the end thereof the following new item: "1508. Jurisdiction for certain partnership proceedings." SEC. 403. REQUIREMENT THAT STATEMENT BE FURNISHED TO PARTNER.

(a) GENERAL RULE.—Section 6031 (relating to return of partner- 26 USC 6031. ship income) is amended by adding at the end thereof the following new subsection: "(b) COPIES TO PARTNERS.—Each partnership required to file a return under subsection (a) for any partnership taxable year shall (on or before the day on which the return for such taxable year was filed) furnish to each person who is a partner at any time during such taxable year a copy of such information shown on such return as may be required by regulations." (b) CONFORMING AMENDMENT.—Section 6031 is amended by striking out "Every partnership" and inserting in lieu thereof the following: "(a) GENERAL RULE.—Every partnership". SEC. 404. RETURNS REQUIRED FROM ALL PARTNERSHIPS WITH UNITED STATES PARTNERS.

26 USC 6031 note.

Except as hereafter provided in regulations prescribed by the Secretary of the Treasury or his delegate, nothing in section 6031 of the Internal Revenue Code of 1954 shall be treated as excluding any partnership from the filing requirements of such section for any taxable year if the income tax liability under subtitle A of such Code 26 USC 1. of any United States person is determined in whole or in part by taking into account (directly or indirectly) partnership items of such partnership for such taxable year. SEC. 405. RETURN REQUIREMENT FOR UNITED STATES PERSONS HAVING INTEREST IN FOREIGN PARTNERSHIPS.

(a) IN GENERAL.—Subpart B of part III of subchapter A of chapter 61 (relating to information concerning transactions with other persons) is amended by inserting after section 6046 the following new section:

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