(a) General rule.— A partnership may file a request for an administrative adjustment of partnership items for any partnership taxable year at any time:(1) Within four (4) 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) Secretary 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 § 33420 of this title.-If the period described in section § 33420(a) of this title is extended pursuant to an agreement under § 33420(b) of this title, the period prescribed by subsection (a)(1) of this section shall not expire before six (6) months after the expiration of the extension under section § 33420(b) of this title. History —Jan. 31, 2011, No. 1, added as § 6100.08 on Dec. 10, 2011, No. 232, § 186.