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Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States

See IRM 21.7.4.4.2.8.1.1, Large Partnership Penalty for Failing to File Electronically, and IRM 20.1.2.5, Failure to File Partnership Return Using Electronic Media, for more information on partnerships that are required to file electronically.

For years ending December 31, 2000 and later, IRC 6011(e)(6) requires partnerships with more than 100 partners to file electronically, unless an exception applies. Treas. Reg. 301.6011-3(c) provides for a penalty for partnerships that fail to file electronically when required to do so. (See information concerning waivers for this requirement in IRM 21.7.4.4.2.8.1.2, Waiver Requests by Large Partnerships Required to File Electronically, and IRM 20.1.2.5.1, Penalty Relief).

If a partnership is required to file their return electronically and they fail to do so, a penalty will be assessed for each schedule K-1 over 100. See the table below for a list of penalty amounts by year:

For Returns Due

Penalty Per Partner in Excess of 100

Higher Maximum Penalty

Lower Maximum Penalty

In 2026

$340

$4,098,500,

$1,366,000

In 2025

$330

$3,987,000

$1,329,000

In 2024

$310

$3,783,000

$1,261,000

In 2023

$290

$3,523,500

$1,777,500

In 2022

$280

$3,426,000

$1,142,000

In 2021

$280

$3,392,000

$1,130,500

In 2020

$270

$3,339,000

$1,113,000

In 2019

$270

$3,275,500

$1,091,500

In 2018

$260

$3,218,500

$1,072,500

In 2017

$260

$3,193,000

$1,064,000

In 2016

$260

$3,178,500

$1,059,500

Between January 1, 2011 & December 31, 2015

$100

$1,500,000

$500,000

Before January 1, 2011

$50

$250,000

$100,000

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