,i #aadth ,,congress #ast ,session ,h4 ,r4 #bhba ,,in ,,the ,,house ,,of ,,representatives ,june #ah1 #bjae ,mr4 ,renacci 7for himself and ,mr4 ,kind7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to reform partnership audit rules4 #a4 ,short title ,this ,act may be cited as the ,partnership ,audit ,simplification ,act of #bjae4 #b4 ,partnership audits and adjustments 7a7 ,repeal of ,,tefra partnership audit rules ,chapter #fc of the ,internal ,revenue ,code of #aihf is amended by striking subchapter ,c 7and by striking the item relating to such subchapter in the table of subchapters for such chapter74 7b7 ,repeal of electing large partnership rules 7#a7 ,in general ,subchapter ,k of chapter #a of such ,code is amended by striking part ,,iv 7and by striking the item relating to such part in the table of parts for such subchapter74 7#b7 ,assessment rules relating to electing large partnerships ,chapter #fc of such ,code is amended by striking subchapter ,d 7and by striking the item relating to such subchapter in the table of subchapters for such chapter74 7c7 ,partnership audit reform 7#a7 ,in general ,chapter #fc of such ,code1 as amended by the preceding provisions of this section1 is amended by inserting after subchapter ,b the following new subchapter3 ,c ,treatment of partnerships ,part ,i--,in general ,part ,,ii--,partnership adjustments ,part ,,iii--,procedure ,part ,,iv--,definitions and special rules ,i ,in general ,sec4 #fbba4 ,determination at partnership level4 ,sec4 #fbbb4 ,partner's return must be consistent with partnership return4 ,sec4 #fbbc4 ,designation of partnership representative4 #fbba4 ,determination at partnership level 7a7 ,in general ,items of income1 gain1 loss1 deduction1 or credit of a partnership for a partnership taxable year 7and any partner's distributive share thereof7 shall be audited1 any tax attributable thereto shall be assessed and collected1 and the applicability of any penalty1 addition to tax1 or additional amount which relates to an adjustment to any such item or share shall be determined1 at the partnership level pursuant to this subchapter4 7b7 ,election out for certain partnerships with #ajj or fewer partners ,this subchapter shall not apply with respect to any partnership for any taxable year if-- 7#a7 the partnership elects the application of this subsection for such taxable year1 7#b7 the partnership has #ajj or fewer partners on the last day of such taxable year1 7#c7 each of the partners of such partnership is an individual1 a ,c corporation 7other than a real estate investment trust or a regulated investment company71 any foreign entity that would be treated as a ,c corporation were it domestic1 or an estate of a deceased partner1 7#d7 the election-- 7,a7 is made with a timely filed return for such taxable year1 and 7,b7 includes 7in the manner prescribed by the ,secretary7 a disclosure of the name and taxpayer identification number of each partner of such partnership1 and 7#e7 the partnership notifies each such partner of such election in the manner prescribed by the ,secretary4 ,for purposes of paragraph 7#d77;,b71 the ,secretary may provide for alternative identification of any foreign partners4 #fbbb4 ,partner's return must be consistent with partnership return 7a7 ,in general ,a partner of any partnership shall1 on the partner's return1 treat each item of income1 gain1 loss1 deduction1 or credit attributable to such partnership in a manner which is consistent with the treatment of such income1 gain1 loss1 deduction1 or credit on the partnership return4 7b7 ,underpayment due to inconsistent treatment assessed as math error ,any underpayment of tax by a partner by reason of failing to comply with the requirements of subsection 7a7 shall be assessed and collected in the same manner as if such underpayment were on account of a mathematical or clerical error appearing on the partner's return4 ,paragraph 7#b7 of section #fbac7;b7 shall not apply to any assessment of an underpayment referred to in the preceding sentence4 7c7 ,addition to tax for failure ,to comply with section ,for addition to tax in the case of partner's disregard of the requirements of this section1 see part ,,ii of subchapter ,a of chapter #fh4 #fbbc4 ,partners bound by actions of partnership 7a7 ,designation of partner ,each partnership shall designate 7in the manner prescribed by the ,secretary7 a partner 7or other person7 as the partnership representative who shall have the sole authority to act on behalf of the partnership under this subchapter4 ,in any case in which such a designation is not in effect1 the ,secretary may select any partner as the partnership representative4 7b7 ,binding effect ,a partnership and all partners of such partnership shall be bound-- 7#a7 by actions taken under this subchapter by the partnership1 and 7#b7 by any decision in a proceeding brought under this subchapter4 ,,ii ,partnership adjustments ,sec4 #fbbe4 ,partnership adjustment by ,secretary4 ,sec4 #fbbf4 ,administrative adjustment request by partnership4 #fbbe4 ,partnership adjustment by ,secretary 7a7 ,in general ,in the case of any adjustment by the ,secretary in the amount of any item of income1 gain1 loss1 deduction1 or credit of a partnership1 or any partner's distributive share thereof-- 7#a7 the partnership shall pay any imputed underpayment with respect to such adjustment in the adjustment year as provided in section #fbcb1 and 7#b7 any imputed overpayment shall be taken into account by the partnership in the adjustment year as a reduction in non-separately stated income or an increase in non-separately stated loss 7whichever is appropriate7 under section #gjb7;a77#h74 7b7 ,determination of imputed underpayments and overpayments ,for purposes of this subchapter-- 7#a7 ,in general ,except as provided in subsection 7c71 any imputed underpayment or imputed overpayment with respect to any partnership adjustment for any reviewed year shall be determined-- 7,a7 by netting all adjustments of items of income1 gain1 loss1 or deduction and multiplying such net amount by the highest rate of tax in effect for the reviewed year under section #a or #aa1 7,b7 by treating any net increase or decrease in loss under subparagraph 7,a7 as a decrease or increase1 respectively1 in income1 and 7,c7 by taking into account any adjustments to items of credit as an increase or decrease1 as the case may be1 in the amount determined under subparagraph 7,a74 7#b7 ,adjustments to distributive shares of partners not netted ,in the case of any adjustment which reallocates the distributive share of any item from one partner to another1 such adjustment shall be taken into account under paragraph 7#a7 by disregarding-- 7,a7 any decrease in any item of income or gain1 and 7,b7 any increase in any item of deduction1 loss1 or credit4 7c7 ,modification of imputed underpayments 7#a7 ,method in general ,the ,secretary shall establish procedures under which the imputed underpayment amount may be modified consistent with the requirements of this subsection4 7#b7 ,amended returns of partners ,such procedures shall provide that if-- 7,a7 one or more partners file returns for the taxable year of the partners which includes the end of the reviewed year of the partnership1 7,b7 such returns take into account all adjustments under subsection 7a7 properly allocable to such partners 7and for any other taxable year with respect to which any tax attribute is affected by reason of such adjustments71 and 7,c7 payment of any tax due is included with such return1 then the imputed underpayment amount shall be determined without regard to the portion of the adjustments so taken into account4 7#c7 ,reallocation of distributive share ,in the case of any adjustment which reallocates the distributive share of any item from one partner to another1 paragraph 7#b7 shall apply only if returns are filed by all partners affected by such adjustment4 7#d7 ,year and day for submission to ,secretary ,anything required to be submitted pursuant to paragraph 7#a7 shall be submitted to the ,secretary not later than the close the #bgj-;day period beginning on the date on which the notice of a proposed partnership adjustment is mailed under section #fbca unless such period is extended with the consent of the ,secretary4 7#e7 ,decision of ,secretary ,any modification of the imputed underpayment amount under this subsection shall be made only upon approval of such modification by the ,secretary4 7d7 ,definitions and special rule ,for purposes of this subchapter-- 7#a7 ,reviewed year ,the term reviewed year means the partnership taxable year to which the item being adjusted relates4 7#b7 ,adjustment year ,the term adjustment year means the partnership taxable year in which-- 7,a7 in the case of an adjustment pursuant to the decision of a court in a proceeding brought under section #fbcd1 such decision becomes final1 7,b7 in the case of an administrative adjustment request under section #fbbf1 such administrative adjustment request is made1 or 7,c7 in any other case1 notice of the final partnership adjustment is mailed under section #fbca4 #fbbf4 ,administrative adjustment request by partnership 7a7 ,in general ,a partnership may file a request for an administrative adjustment in the amount of any item of income1 gain1 loss1 deduction1 or credit of the partnership for any partnership taxable year1 but only to the extent the adjustment results in an imputed underpayment4 7b7 ,adjustment ,any such adjustment under subsection 7a7 shall be determined and taken into account by the partnership under rules similar to the rules of section #fbbe 7other than subsection 7c7 thereof7 for the partnership taxable year in which the administrative adjustment request is made4 7c7 ,period of limitations ,a partnership may not file such a request-- 7#a7 more than #c years after the later of-- 7,a7 the date on which the partnership return for such year is filed1 or 7,b7 the last day for filing the partnership return for such year 7determined without regard to extensions71 and 7#b7 after any notice of an administrative proceeding with respect to the taxable year is mailed under section #fbca4 ,,iii ,procedure ,sec4 #fbca4 ,notice of proceedings and adjustment4 ,sec4 #fbcb4 ,assessment1 collection1 and payment4 ,sec4 #fbcc4 ,penalties and interest4 ,sec4 #fbcd4 ,judicial review of partnership adjustment4 ,sec4 #fbce4 ,period of limitations on making adjustments4 #fbca4 ,notice of proceedings and adjustment 7a7 ,in general ,the ,secretary shall mail to the partnership and the partnership representative-- 7#a7 notice of any administrative proceeding initiated at the partnership level with respect to an adjustment of any item of income1 gain1 loss1 deduction1 or credit of a partnership for a partnership taxable year1 or any partner's distributive share thereof1 7#b7 notice of any proposed partnership adjustment resulting from such proceeding1 and 7#c7 notice of any final partnership adjustment resulting from such proceeding4 ,any notice of a final partnership adjustment shall not be mailed earlier than #bgj days after the date on which the notice of the proposed partnership adjustment is mailed4 ,such notices shall be sufficient if mailed to the last known address of the partnership representative or the partnership 7even if the partnership has terminated its existence74 ,the first sentence shall apply to any proceeding with respect to an administrative adjustment request filed by a partnership under section #fbbf4 7b7 ,further notices restricted ,if the ,secretary mails a notice of a final partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under section #fbcd with respect to such notice1 in the absence of a showing of fraud1 malfeasance1 or misrepresentation of a material fact1 the ,secretary shall not mail another such notice to such partnership with respect to such taxable year4 7c7 ,authority ,to rescind notice with partnership consent ,the ,secretary may1 with the consent of the partnership1 rescind any notice of a partnership adjustment mailed to such partnership4 ,any notice so rescinded shall not be treated as a notice of a partnership adjustment for purposes of this subchapter1 and the taxpayer shall have no right to bring a proceeding under section #fbcd with respect to such notice4 #fbcb4 ,assessment1 collection1 and payment 7a7 ,in general ,any imputed underpayment-- 7#a7 shall be assessed and collected in the same manner as if it were a tax imposed for the adjustment year by subtitle ,a1 and 7#b7 shall be paid on or before the partnership return due date for the adjustment year4 7b7 ,limitation on assessment ,except as otherwise provided in this chapter1 no assessment of a deficiency may be made 7and no levy or proceeding in any court for the collection of any amount resulting from such adjustment may be made1 begun or prosecuted7 before-- 7#a7 the close of the #ijth day after the day on which a notice of a final partnership adjustment was mailed1 and 7#b7 if a petition is filed under section #fbcd with respect to such notice1 the decision of the court has become final4 7c7 ,premature action may be enjoined ,notwithstanding section #gdba7;a71 any action which violates subsection 7b7 may be enjoined in the proper court1 including the ,tax ,court4 ,the ,tax ,court shall have no jurisdiction to enjoin any action under this subsection unless a timely petition has been filed under section #fbcd and then only in respect of the adjustments that are the subject of such petition4 7d7 ,exceptions to restrictions on adjustments 7#a7 ,adjustments arising out of math or clerical errors 7,a7 ,in general ,if the partnership is notified that1 on account of a mathematical or clerical error appearing on the partnership return1 an adjustment to a item is required1 rules similar to the rules of paragraphs 7#a7 and 7#b7 of section #fbac7;b7 shall apply to such adjustment4 7,b7 ,special rule ,if a partnership is a partner in another partnership1 any adjustment on account of such partnership's failure to comply with the requirements of section #fbbb7;a7 with respect to its interest in such other partnership shall be treated as an adjustment referred to in subparagraph 7,a71 except that paragraph 7#b7 of section #fbac7;b7 shall not apply to such adjustment4 7#b7 ,partnership may waive restrictions ,the partnership may at any time 7whether or not any notice of partnership adjustment has been issued71 by a signed notice in writing filed with the ,secretary1 waive the restrictions provided in subsection 7b7 on the making of any partnership adjustment4 7e7 ,limit where no proceeding begun ,if no proceeding under section #fbcd is begun with respect to any notice of a final partnership adjustment during the #ij-;day period described in subsection 7b7 thereof1 the amount for which the partnership is liable under section #fbbe shall not exceed the amount determined in accordance with such notice4 #fbcc4 ,penalties and interest 7a7 ,penalties and interest determined from reviewed year 7#a7 ,in general ,in the case of an imputed underpayment with respect to a partnership adjustment for a reviewed year1 the partnership-- 7,a7 shall pay to the ,secretary interest computed under paragraph 7#b71 and 7,b7 shall be liable for any penalty1 addition to tax1 or additional amount as provided in paragraph 7#c74 7#b7 ,determination of amount of interest ,the interest computed under this paragraph with respect to any partnership adjustment is the interest which would be determined under chapter #fg-- 7,a7 on the imputed underpayment determined with respect to such adjustment1 7,b7 for the period beginning on the day after the return due date for the reviewed year and ending on the return due date for the adjustment year 7or1 if earlier1 the date payment of the imputed underpayment is made74 ,proper adjustments in the amount determined under the preceding sentence shall be made for adjustments required for partnership taxable years after the reviewed year and before the adjustment year by reason of such partnership adjustment4 7#c7 ,penalties ,a partnership shall be liable for any penalty1 addition to tax1 or additional amount for which it would have been liable if such partnership had been an individual subject to tax under chapter #a for the reviewed year and the imputed underpayment were an actual underpayment 7or understatement7 for such year4 7b7 ,interest and penalties with respect to adjustment year return 7#a7 ,in general ,in the case of any failure to pay an imputed underpayment on the date prescribed therefor1 the partnership shall be liable-- 7,a7 for interest as determined under paragraph 7#b71 and 7,b7 for any penalty1 addition to tax1 or additional amount as determined under paragraph 7#c74 7#b7 ,interest ,interest determined under this paragraph is the interest that would be determined by treating the imputed underpayment as an underpayment of tax imposed in the adjustment year4 7#c7 ,penalties ,penalties1 additions to tax1 or additional amounts determined under this paragraph are the penalties1 additions to tax1 or additional amounts that would be determined-- 7,a7 by applying section #ffea7;a77#b7 to such failure to pay4 7,b7 by treating the imputed underpayment as an underpayment of tax for purposes of part ,,ii of subchapter ,a of chapter #fh4 #fbcd4 ,judicial review of partnership adjustment 7a7 ,in general ,within #ij days after the date on which a notice of a final partnership adjustment is mailed under section #fbca with respect to any partnership taxable year1 the partnership may file a petition for a readjustment for such taxable year with-- 7#a7 the ,tax ,court1 7#b7 the district court of the ,united ,states for the district in which the partnership's principal place of business is located1 or 7#c7 the ,claims ,court4 7b7 ,jurisdictional requirement for bringing action in district court or ,claims ,court 7#a7 ,in general ,a readjustment petition under this section may be filed in a district court of the ,united ,states or the ,claims ,court only if the partnership filing the petition deposits with the ,secretary1 on or before the date the petition is filed1 the amount of the imputed underpayment 7as of the date of the filing of the petition7 if the partnership adjustment was made as provided by the notice of final partnership adjustment4 ,the court may by order provide that the jurisdictional requirements of this paragraph are satisfied where there has been a good faith attempt to satisfy such requirement and any shortfall of the amount required to be deposited is timely corrected4 7#b7 ,interest payable ,any amount deposited under paragraph 7#a71 while deposited1 shall not be treated as a payment of tax for purposes of this title 7other than chapter #fg74 7c7 ,scope of judicial review ,a court with which a petition is filed in accordance with this section shall have jurisdiction to determine all items of income1 gain1 loss1 deduction1 or credit of the partnership for the partnership taxable year to which the notice of final partnership adjustment relates1 the proper allocation of such items among the partners1 and the applicability of any penalty1 addition to tax1 or additional amount for which the partnership may be liable under this subchapter4 7d7 ,determination of court reviewable ,any determination by a court under this section shall have the force and effect of a decision of the ,tax ,court or a final judgment or decree of the district court or the ,claims ,court1 as the case may be1 and shall be reviewable as such4 ,the date of any such determination shall be treated as being the date of the court's order entering the decision4 7e7 ,effect of decision dismissing action ,if an action brought under this section is dismissed other than by reason of a rescission under section #fbca7;c71 the decision of the court dismissing the action shall be considered as its decision that the notice of final partnership adjustment is correct1 and an appropriate order shall be entered in the records of the court4 #fbce4 ,period of limitations on making adjustments 7a7 ,in general ,except as otherwise provided in this section1 no adjustment under this subpart for any partnership taxable year may be made after the later of-- 7#a7 the date which is #c years after the latest of-- 7,a7 the date on which the partnership return for such taxable year was filed1 7,b7 the return due date for the taxable year1 or 7,c7 the date on which the partnership filed an administrative adjustment request with respect to such year under section #fbbf1 or 7#b7 in the case of any modification of an imputed underpayment under section #fbbe7;c71 the date that is #bgj days 7plus the number of days of any extension consented to by the ,secretary under paragraph 7#d7 thereof7 after the date on which everything required to be submitted to the ,secretary pursuant to such section is so submitted4 7b7 ,extension by agreement ,the period described in subsection 7a7 7including an extension period under this subsection7 may be extended by an agreement entered into by the ,secretary and the partnership before the expiration of such period4 7c7 ,special rule in case of fraud1 etc 7#a7 ,false return ,in the case of a false or fraudulent partnership return with intent to evade tax1 the adjustment may be made at any time4 7#b7 ,substantial omission of income ,if any partnership omits from gross income an amount properly includible therein and such amount is described in section #feja7;e77#a77;,a71 subsection 7a7 shall be applied by substituting #f years for #c years4 7#c7 ,no return ,in the case of a failure by a partnership to file a return for any taxable year1 the adjustment may be made at any time4 7#d7 ,return filed by ,secretary ,for purposes of this section1 a return executed by the ,secretary under subsection 7b7 of section #fjbj on behalf of the partnership shall not be treated as a return of the partnership4 7d7 ,suspension when ,secretary mails notice of adjustment ,if notice of a final partnership adjustment with respect to any taxable year is mailed under section #fbca1 the running of the period specified in subsection 7a7 7as modified by the other provisions of this section7 shall be suspended-- 7#a7 for the period during which an action may be brought under section #fbcd 7and1 if a petition is filed under such section with respect to such notice1 until the decision of the court becomes final71 and 7#b7 for #a year thereafter4 ,,iv ,definitions and special rules ,sec4 #fbda4 ,definitions and special rules4 #fbda4 ,definitions and special rules 7a7 ,definitions and special rules ,for purposes of this subchapter-- 7#a7 ,partnership ,the term partnership means any partnership required to file a return under section #fjca7;a74 7#b7 ,partner ,the term partner means-- 7,a7 a partner in the partnership1 and 7,b7 any other person whose income tax liability under subtitle ,a is determined in whole or in part by taking into account directly or indirectly income1 gain1 deduction1 or loss of the partnership4 7b7 ,partnership adjustment ,the term partnership adjustment means any adjustment in the amount of any item of income1 gain1 loss1 deduction1 or credit of a partnership1 or any partner's distributive share thereof4 7c7 ,return due date ,the term return due date means1 with respect to the taxable year1 the date prescribed for filing the partnership return for such taxable year 7determined without regard to extensions74 7d7 ,joint and several liability 7#a7 ,in general ,the partnership and any partner of the partnership shall be jointly and severally liable for any imputed underpayment and any penalty1 addition to tax1 or additional amount attributable thereto4 7#b7 ,period for assessment of partners ,the period for assessment of an imputed underpayment with respect to a partner of a partnership shall not expire earlier than #c years after the date on which an assessment of such imputed underpayment was made with respect to the partnership4 7#c7 ,determining partners ,a person shall be treated as partner of the partnership if such person is a partner of such partnership at any time during the reviewed or adjustment year4 7e7 ,payments nondeductible ,no deduction shall be allowed under subtitle ,a for any payment required to be made by a partnership under this subchapter4 7f7 ,special rule for deductions1 losses1 and credits of foreign partnerships ,except to the extent otherwise provided in regulations1 in the case of any partnership the partnership representative of which resides outside the ,united ,states or the books of which are maintained outside the ,united ,states1 no deduction1 loss1 or credit shall be allowable to any partner unless section #fjca is complied with for the partnership's taxable year in which such deduction1 loss1 or credit arose at such time as the ,secretary prescribes by regulations4 7g7 ,partnerships having principal place of business outside ,united ,states ,for purposes of sections #fbcd1 a principal place of business located outside the ,united ,states shall be treated as located in the ,district of ,columbia4 7h7 ,partnerships in cases under title #aa of ,united ,states ,code 7#a7 ,suspension of period of limitations on making adjustment1 assessment1 or collection ,the running of any period of limitations provided in this subchapter on making a partnership adjustment 7or provided by section #feja or #fejb on the assessment or collection of any imputed underpayment determined under this subchapter7 shall1 in a case under title #aa of the ,united ,states ,code1 be suspended during the period during which the ,secretary is prohibited by reason of such case from making the adjustment 7or assessment or collection7 and-- 7,a7 for adjustment or assessment1 #fj days thereafter1 and 7,b7 for collection1 #f months thereafter4 ,a rule similar to the rule of section #fbac7;f77#b7 shall apply for purposes of section #fbcb7;b74 7#b7 ,suspension of period of limitation for filing for judicial review ,the running of the period specified in section #fbcd shall1 in a case under title #aa of the ,united ,states ,code1 be suspended during the period during which the partnership is prohibited by reason of such case from filing a petition under section #fbcd and for #fj days thereafter4 7i7 ,treatment where partnership ceases ,to exist ,if a partnership ceases to exist before a partnership adjustment under this subchapter takes effect1 such adjustment shall be taken into account by the former partners of such partnership under regulations prescribed by the ,secretary4 4 7#b7 ,clerical amendment ,the table of subchapters for chapter #fc of such ,code1 as amended by the preceding provisions of this section1 is amended by inserting after the item relating to subchapter ,b the following new items3 ,subchapter ,c4 ,treatment of partnerships4 4 7d7 ,conforming amendments 7#a7 ,section #fjca7;b7 of such ,code is amended by striking the last sentence4 7#b7 ,section #fdbb of such ,code is amended by striking paragraph 7#ab74 7#c7 ,section #feja7n7 of such ,code is amended by striking paragraphs 7#b7 and 7#c7 and by striking ,cross references and all that follows through ,for period of limitations and inserting ,cross reference4--,for period of limitations4 7#d7 ,section #fejc7;a77#a7 of such ,code is amended by striking 7or section #fbbi and all that follows through of section #fbcj7;a774 7#e7 ,section #fejd of such ,code is amended by striking paragraph 7#aa74 7#f7 ,section #feaa of such ,code is amended by striking subsection 7g74 7#g7 ,section #feab7;b77#c7 of such ,code is amended by striking the second sentence4 7#h7 ,section #feae of such ,code is amended by striking paragraph 7#f74 7#i7 ,section #ffja7;c7 of such ,code is amended by striking the last sentence4 7#aj7 ,section #gdba7;a7 of such ,code is amended by striking #fbbe7;b71 #fbdf7;b7 and inserting #fbcb7;c74 7#aa7 ,section #gdbb of such ,code is amended by striking subsection 7h74 7#ab7 ,section #gdei7;c7 of such ,code is amended by striking section #fbbf and all that follows through or #fbeb and inserting section #fbcd4 7#ac7 ,section #gdhb7;b77#a7 of such ,code is amended-- 7,a7 in subparagraph 7,e71 by striking section #fbbf1 #fbbh1 #fbdg1 or #fbeb and inserting section #fbcd1 7,b7 by striking subparagraph 7,f71 by striking or at the end of subparagraph 7,e7 and inserting a period1 and by inserting or at the end of subparagraph 7,d71 and 7,c7 in the last sentence1 by striking section #fbbf1 #fbbh7;a71 or #fbcd7;c7 and inserting section #fbcd4 7#ad7 ,section #gdhe7;b7 of such ,code is amended by striking section #fbbf1 #fbbh7;a71 #fbdg1 or #fbeb and inserting section #fbcd4 7e7 ,effective date 7#a7 ,in general ,except as provided in paragraph 7#b71 the amendments made by this section shall apply to returns filed for partnership taxable years ending after ,december #ca1 #bjah4 7#b7 ,election ,a partnership may elect 7at such time and in such form and manner as the ,secretary of the ,treasury may prescribe7 for the amendments made by this section 7other than the election under section #fbba7;b7 of such ,code 7as added by this ,act77 to apply to any return of the partnership filed for partnership taxable years ending after the date of the enactment of this ,act and before ,january #a1 #bjai4