(a)

General rule

A partnership may file a request for an administrative adjustment of partnership items for any partnership taxable year at any time which is -

(1)

within 3 years after the later of -

(A)

the date on which the partnership return for such year is filed, or

(B)

the last day for filing the partnership return for such year (determined without regard to extensions), and

(2)

before the mailing to the partnership of a notice of a partnership adjustment with respect to such taxable year.

(b)

Secretarial action

If a partnership files an administrative adjustment request under subsection (a), the Secretary may allow any part of the requested adjustments.

(c)

Special rule in case of extension under section 6248

If the period described in section 6248(a) is extended pursuant to an agreement under section 6248(b), the period prescribed by subsection (a)(1) shall not expire before the date 6 months after the expiration of the extension under section 6248(b).