103 
(3) SPECIAL RULES FOR APPLICATION OF REA-
SONABLE CAUSE EXCEPTION.—Subsection (c) of sec-
tion 6664 is amended— 
(A) by redesignating paragraphs (2) and 
(3) as paragraphs (3) and (4), respectively, 
(B) by striking ‘‘paragraph (2)’’ in para-
graph (4), as so redesignated, and inserting 
‘‘paragraph (3)’’, and 
(C) by inserting after paragraph (1) the 
following new paragraph: 
‘‘(2) SPECIAL RULE FOR UNDERPAYMENTS AT-
TRIBUTABLE TO INVESTMENT MANAGEMENT SERV-
ICES.— 
‘‘(A) IN
GENERAL.—Paragraph (1) shall 
not apply to any portion of an underpayment to 
which this section applies by reason of sub-
section (b)(7) unless— 
‘‘(i) the relevant facts affecting the 
tax treatment of the item are adequately 
disclosed, 
‘‘(ii) there is or was substantial au-
thority for such treatment, and 
‘‘(iii) the taxpayer reasonably believed 
that such treatment was more likely than 
not the proper treatment.
104 
‘‘(B) RULES
RELATING
TO
REASONABLE 
BELIEF.—Rules similar to the rules of sub-
section (d)(3) shall apply for purposes of sub-
paragraph (A)(iii).’’. 
(d) INCOME AND LOSS FROM INVESTMENT SERVICES 
PARTNERSHIP INTERESTS TAKEN INTO ACCOUNT IN DE-
TERMINING NET EARNINGS FROM SELF-EMPLOYMENT.— 
(1) 
INTERNAL
REVENUE
CODE.—Section 
1402(a) is amended by striking ‘‘and’’ at the end of 
paragraph (16), by striking the period at the end of 
paragraph (17) and inserting ‘‘; and’’, and by insert-
ing after paragraph (17) the following new para-
graph: 
‘‘(18) notwithstanding the preceding provisions 
of this subsection, in the case of any individual en-
gaged in the trade or business of providing services 
described in section 710(c)(1) with respect to any 
entity, any amount treated as ordinary income or or-
dinary loss of such individual under section 710 with 
respect to such entity shall be taken into account in 
determining the net earnings from self-employment 
of such individual.’’. 
(2) SOCIAL SECURITY ACT.—Section 211(a) of 
the Social Security Act is amended by inserting after 
paragraph (16) the following new paragraph:
105 
‘‘(17) Notwithstanding the preceding provisions 
of this subsection, in the case of any individual en-
gaged in the trade or business of providing services 
described in section 710(c)(1) of the Internal Rev-
enue Code of 1986 with respect to any entity, any 
amount treated as ordinary income or ordinary loss 
of such individual under section 710 of such Code 
with respect to such entity shall be taken into ac-
count in determining the net earnings from self-em-
ployment of such individual.’’. 
(e) CONFORMING AMENDMENTS.— 
(1) Subsection (d) of section 731 is amended by 
inserting ‘‘section 710(b)(4) (relating to distribu-
tions of partnership property),’’ after ‘‘to the extent 
otherwise provided by’’. 
(2) Section 741 is amended by inserting ‘‘or 
section 710 (relating to special rules for partners 
providing investment management services to part-
nership)’’ before the period at the end. 
(3) The table of sections for part I of sub-
chapter K of chapter 1 is amended by adding at the 
end the following new item: 
‘‘Sec. 710. Special rules for partners providing investment management services 
to partnership.’’. 
(f) EFFECTIVE DATE.—
106 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to taxable years ending after 
December 31, 2009. 
(2) PARTNERSHIP TAXABLE YEARS WHICH IN-
CLUDE
EFFECTIVE
DATE.—In applying section 
710(a) of the Internal Revenue Code of 1986 (as 
added by this section) in the case of any partnership 
taxable year which includes December 31, 2009, the 
amount of the net income referred to in such section 
shall be treated as being the lesser of the net income 
for the entire partnership taxable year or the net in-
come determined by only taking into account items 
attributable to the portion of the partnership taxable 
year which is after such date. 
(3) DISPOSITIONS
OF
PARTNERSHIP
INTER-
ESTS.—Section 710(b) of the Internal Revenue Code 
of 1986 (as added by this section) shall apply to dis-
positions and distributions after December 31, 2009. 
(4) OTHER INCOME AND GAIN IN CONNECTION 
WITH INVESTMENT MANAGEMENT SERVICES.—Sec-
tion 710(d) of such Code (as added by this section) 
shall take effect on January 1, 2010.
107 
(5) PUBLICLY
TRADED
PARTNERSHIPS.—The 
amendment made by subsection (b) shall apply to 
taxable years beginning after December 31, 2009. 
Subtitle B—Time for Payment of 
Corporate Estimated Taxes 
SEC. 611. TIME FOR PAYMENT OF CORPORATE ESTIMATED 
TAXES. 
The percentage under paragraph (1) of section 
202(b) of the Corporate Estimated Tax Shift Act of 2009 
in effect on the date of the enactment of this Act is in-
creased by 26.5 percentage points. 
Subtitle C—Tax Expenditure Study 
SEC. 621. FINDINGS. 
Congress finds the following: 
(1) Currently, the aggregate cost of Federal tax 
expenditures rivals, or even exceeds, the amount of 
total Federal discretionary spending. 
(2) Given the escalating public debt, a critical 
examination of this use of taxpayer dollars is essen-
tial. 
(3) Additionally, tax expenditures can com-
plicate the Internal Revenue Code of 1986 for tax-
payers and complicate tax administration for the In-
ternal Revenue Service.
108 
(4) To facilitate a better understanding of tax 
expenditures in the future, it is constructive for leg-
islation extending these provisions to include a study 
of such provisions.
SEC. 622. STUDY OF EXTENDED TAX EXPENDITURES. 
(a) IN GENERAL.—Not later than November 30, 
2010, the Chief of Staff of the Joint Committee on Tax-
ation, in consultation with the Comptroller General of the 
United States, shall submit to the Committee on Ways 
and Means of the House of Representatives and the Com-
mittee on Finance of the Senate a report on each tax ex-
penditure (as defined in section 3(3) of the Congressional 
Budget Impoundment Control Act of 1974 (2 U.S.C. 
622(3)) extended by this Act. 
(b) ROLLING SUBMISSION OF REPORTS.—The Chief 
of Staff of the Joint Committee on Taxation shall initially 
submit the reports for each such tax expenditure enacted 
in subtitle B of title I (relating to business tax relief) and 
title IV (relating to energy provisions) in order of the tax 
expenditure incurring the least aggregate cost to the 
greatest aggregate cost (determined by reference to the 
cost estimate of this Act by the Joint Committee on Tax-
ation). Thereafter, such reports may be submitted in such 
order as the Chief of Staff determines appropriate.