adjustment yearmeans the partnership taxable year in which—
audited partnershipmeans, with respect to any partner described in subparagraph (A), the partnership in the chain of ownership originally electing the application of this section.
deficiencymeans the amount by which the tax imposed by subtitle A or B, or chapter 41, 42, 43, or 44 exceeds the excess of—
mathematical or clerical errormeans— A taxpayer shall be treated as having omitted a correct TIN for purposes of the preceding sentence if information provided by the taxpayer on the return with respect to the individual whose TIN was provided differs from the information the Secretary obtains from the person issuing the TIN.
partnershipmeans any partnership required to file a return under section 6031(a).
partnership adjustmentmeans any adjustment to a partnership-related item.
rebatemeans so much of an abatement, credit, refund, or other repayment, as was made on the ground that the tax imposed by subtitle A or B or chapter 41, 42, 43, or 44 was less than the excess of the amount specified in subsection (a)(1) over the rebates previously made.
returnincludes any return, statement, schedule, or list, and any amendment or supplement thereto, filed with respect to any tax imposed by subtitle A or B, or chapter 41, 42, 43, or 44.
return due datemeans, with respect to the taxable year, the date prescribed for filing the partnership return for such taxable year (determined without regard to extensions).
reviewed yearmeans the partnership taxable year to which the item being adjusted relates.
specified partnermeans any person if such person— with respect to each taxable year of such person which is during the period beginning with the taxable year of such person in which or with which the reviewed year of such publicly traded partnership ends and ending with the taxable year of such person in which or with which the adjustment year of such publicly traded partnership ends.
specified passive activity lossmeans, with respect to any specified partner of such publicly traded partnership, the lesser of—