(a) General rule.— The Secretary is authorized and directed to make adjustments at the partnership level in any partnership item to the extent necessary to have such item be treated in the manner required.(b) Notice of partnership adjustment.—(1) In general.— If the Secretary determines that a partnership adjustment is required, the Secretary is authorized to send notice of such adjustment to the partnership by certified mail. Such notice shall be sufficient if mailed to the partnership at its last known address even if the partnership has terminated its existence.(2) Further notices restricted.— If the Secretary sends a notice of a partnership adjustment to any partnership for any partnership taxable year and the partnership files a petition under § 33419 of this title with respect to such notice, in the absence of a showing of fraud, malfeasance, or misrepresentation of a material fact, the Secretary shall not send another such notice to such partnership with respect to such taxable year.(3) Authority to rescind notice with partnership consent.— The Secretary may, with the consent of the partnership, rescind any notice of a partnership adjustment sent to such partnership.

axable year.(3) Authority to rescind notice with partnership consent.— The Secretary may, with the consent of the partnership, rescind any notice of a partnership adjustment sent to such partnership. Any notice so rescinded shall not be treated as a notice of a partnership adjustment, for purposes of this section, §§ 33418 and 33419 of this title, with respect to such notice. Nothing in this subsection shall affect any suspension of the running of any period of limitations during any period during which the rescinded notice was outstanding. History —Jan. 31, 2011, No. 1, added as § 6100.04 on Dec. 10, 2011, No. 232, § 186.