Partner’s return must be consistent with partnership return

A partner shall, on the partner’s return, treat any partnership-related item in a manner which is consistent with the treatment of such item on the partnership return. Any underpayment of tax by a partner by reason of failing to comply with the requirements of subsection (a) shall be assessed and collected in the same manner as if such underpayment were on account of a mathematical or clerical error appearing on the partner’s return. Paragraph (2) of section 6213(b) shall not apply to any assessment of an underpayment referred to in the preceding sentence. In the case of any item referred to in subsection (a), if— A partner shall be treated as having complied with subparagraph (B) of paragraph (1) with respect to an item if the partner— Any final decision with respect to an inconsistent position identified under subsection (c) in a proceeding to which the partnership is not a party shall not be binding on the partnership. For addition to tax in the case of a partner’s disregard of the requirements of this section, see part II of subchapter A of chapter 68.