96 STAT. 656
PUBLIC LAW 97-248—SEPT. 3, 1982 "(3) mail to the part n e r, under subparagraph (A) of section 6231(b)(1) (relating to items becoming n o n partnership items), a notice that all partnership items of the part n e r for the partnership taxable year to which such request relates shall be t r e a t e d as n o n partnership items, or "(4) conduct a partnership proceeding.
26 USC 6228.
"SEC. 6228. JUDICIAL REVIEW WHERE ADMINISTRATIVE ADJUSTMENT REQUEST IS NOT ALLOWED IN FULL. "(a) R E Q U E S T ON B E H A L F OF PARTNERSHIP. —
"(1) IN GENERAL.—If any part of an administrative adjustment request filed by the tax m a t t e r s part n e r under subsection (b) of section 6227 is not allowed by the Secretary, the tax m a t t e r s part n e r may file a petition for an adjustment with respect to the partnership items to which such part of the request relates with— "(A) the Tax Court, "(B) the district court of the United States for the district in which the principal place of business of the partnership is located, or "(C) the Claims Court. "(2) PERIOD FOR FILING P E T I T I O N. —
"(A) IN GENERAL.—A petition may be filed under paragraph (1) with respect to partnership items for a partnership taxable year only— "(i) after the expiration of 6 months from the date of filing of the request under section 6227, and "(ii) before the date which is 2 years after the date of such request. "(B) N o PETITION AFTER NOTICE OF B E G I N N I N G OF ADMINIS-
TRATIVE PROCEEDING.—No petition may be filed under paragraph (1) after the day the Secretary mails to the partnership a notice of the beginning of an administrative proceeding with respect to the partnership taxable year to which such request relates. "(C)
F A I L U R E BY SECRETARY TO ISSUE TIMELY NOTICE OF
ADJUSTMENT.—If the Secretary— "(i) mails the notice referred to in subparagraph (B) before the expiration of the 2-year period referred to in clause (ii) of subparagraph (A), and "(ii) fails to mail a notice of final partnership administrative adjustment with respect to the partnership taxable year to which the request relates before the expiration of the period described in section 6229(a) (including any extension by agreement), subparagraph (B) shall cease to apply with respect to such request, and the 2-year period referred to in clause (ii) of subparagraph (A) shall not expire before the date 6 months after the expiration of the period described in section 6229(a) (including any extension by agreement). "(D) EXTENSION OF TIME.—The 2-year period described in subparagraph (A)(ii) shall be extended for such period as may be agreed upon in writing between the tax m a t t e r s part n e r and the Secretary. "(3) COORDINATION WITH ADMINISTRATIVE ADJUSTMENT. — "(A) ADMINISTRATIVE ADJUSTMENT BEFORE FILING OF PETI-
TION.—No petition may be filed under this subsection after
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