Sec. 202. Determination of imputed underpayments
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Section 6225(b) is amended to read as follows: For purposes of this subchapter— Except as otherwise provided in this section, any imputed underpayment with respect to any reviewed year shall be determined by the Secretary by— appropriately netting all partnership adjustments with respect to such reviewed year, and applying the highest rate of tax in effect for the reviewed year under section 1 or 11. In 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.
For 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. If any adjustment would (but for this paragraph)— result in a decrease in the amount of the imputed underpayment, and 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. .
Section 6225(a) is amended to read as follows: In the case of any adjustments by the Secretary to any partnership-related items with respect to any reviewed year of a partnership— 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 if such adjustments do not result in an imputed underpayment, such adjustments shall be taken into account by the partnership in the adjustment year. .
Section 6225(c) is amended by adding at the end the following new paragraph: The Secretary shall establish procedures under which the adjustments described in subsection (a)(2) may be modified in such manner as the Secretary determines appropriate. .