96 STAT. 650
PUBLIC LAW 97-248—SEPT. 3, 1982 "(1) INFORMATION ON PARTNERSHIP RETURN.—Except as provided in paragraphs (2) and (3), the Secretary shall use the names, addresses, and profits interests shown on the partnership return. "(2) USE OF ADDITIONAL INFORMATION.—The Secretary shall use additional information furnished to him by the tax matters partner or any other person in accordance with regulations prescribed by the Secretary. "(3) SPECIAL RULE WITH RESPECT TO INDIRECT PARTNERS.—If
any information furnished to the Secretary under paragraph (1) or (2)— "(A) shows that a person has a profits interest in the partnership by reason of ownership of an interest through 1 or more pass-thru partners, and "(B) contains the name, address, and profits interest of such person, then the Secretary shall use the name, address, and profits interest of such person with respect to such partnership interest (in lieu of the names, addresses, and profits interests of the passthru partners). "(d) PERIOD FOR MAILING NOTICE.— "(1) NOTICE OF BEGINNING OF PROCEEDINGS.—The Secretary
shall mail the notice specified in paragraph (1) of subsection (a) to each partner entitled to such notice not later than the 120th day before the day on which the notice specified in paragraph (2) of subsection (a) is mailed to the tax matters partner. "(2) NOTICE OF FINAL PARTNERSHIP ADMINISTRATIVE ADJUST-
MENT.—The Secretary shall mail the notice specified in paragraph (2) of subsection (a) to each partner entitled to such notice not later than the 60th day after the day on which the notice specified in such paragraph (2) was mailed to the tax matters partner. "(e) EFFECT OF SECRETARY'S FAILURE TO PROVIDE NOTICE.— "(1) APPLICATION OF SUBSECTION.—
"(A) IN GENERAL.—This subsection applies where the Secretary has failed to mail any notice specified in subsection (a) to a partner entitled to such notice within the period specified in subsection (d). "(B) SPECIAL RULES FOR PARTNERSHIPS WITH MORE THAN
100 PARTNERS.—For purposes of subparagraph (A), any partner described in paragraph (1) of subsection (b) shall be treated as entitled to notice specified in subsection (a). The Secretary may provide such notice— "(i) except as provided in clause (ii), by mailing notice to the tax matters partner, or "(ii) in the case of a member of a notice group which qualifies under paragraph (2) of subsection (b), by mailing notice to the partner designated for such purpose by the group. "(2) PROCEEDINGS FINISHED.—In any case to which this subsection applies, if at the time the Secretary mails the partner notice of the proceeding— "(A) the period within which a petition for review of a final partnership administrative adjustment under section 6226 may be filed has expired and no such petition has been filed, or
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