Partner Amended Return Modification Procedure

§ 6225. Partnership adjustment by Secretary(a) In generalIn the case of any adjustments by the Secretary to any partnership-related items with respect to any reviewed year of a partnership—(1) if such adjustments result in an imputed underpayment, the partnership shall pay an amount equal to such imputed underpayment in the adjustment year as provided in section 6232, and (2) if such adjustments do not result in an imputed underpayment, such adjustments shall be taken into account by the partnership in the adjustment year. (b) Determination of imputed underpaymentsFor purposes of this subchapter—(1) In generalExcept as otherwise provided in this section, any imputed underpayment with respect to any reviewed year shall be determined by the Secretary by—(A) appropriately netting all partnership adjustments with respect to such reviewed year, and (B) applying the highest rate of tax in effect for the reviewed year under section 1 or 11. (2) Adjustments to distributive shares of partners not nettedIn the case of any adjustment which reallocates the distributive share of any item from one partner to another, such adjustment shall be taken into account by disregarding so much of such adjustment as results in a decrease in the amount of the imputed underpayment. (3) Adjustments separately netted by categoryFor purposes of paragraph (1)(A), partnership adjustments for any reviewed year shall first be separately determined (and netted as appropriate) within each category of items that are required to be taken into account separately under section 702(a) or other provision of this title. (4) Limitation on adjustments that may be taken into accountIf any adjustment would (but for this paragraph)—(A) result in a decrease in the amount of the imputed underpayment, and (B) could be subject to any additional limitation under the provisions of this title (or not allowed, in whole or in part, against ordinary income) if such adjustment were taken into account by any person, such adjustment shall not be taken into account under paragraph (1)(A) except to the extent otherwise provided by the Secretary. (c) Modification of imputed underpayments(1) In generalThe Secretary shall establish procedures under which the imputed underpayment amount may be modified consistent with the requirements of this subsection. (2) Procedures for partners to take adjustments into account(A) Amended returns of partnersSuch procedures shall provide that if—(i) one or more partners file returns for the taxable year of the partners which includes the end of the reviewed year of the partnership (and for any taxable year with respect to which any tax attribute is affected by reason of any adjustment referred to in clause (ii)), (ii) such returns take into account all adjustments under subsection (a) properly allocable to such partners (and the effect of such adjustments on any tax attributes), and (iii) payment of any tax due is included with such returns,