- 11 - partnership item may not be based upon a concession by the other party with respect to a nonpartnership item. Settlements shall be comprehensive, that is, a settlement may not be limited to selected items. The requirement for consistent settlement terms applies only if-- (1) The items were partnership items for the partner entering into the original settlement immediately before the original settlement, and (2) The items are partnership items for the partner requesting the consistent settlement at the time the partner files the request. [Emphasis supplied.] Participants interpret "settlements" in the regulation as referring only to the consistent settlement terms of partnership items. They maintain that paragraph one of the original settlement agreement constitutes a "settlement agreement * * * with respect to partnership items" for purposes of the consistent settlement provisions and request settlement in accord with paragraph one. This interpretation of section 301.6224(c)-3T(b), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5, 1987), is nothing more than semantical sophistry and would have us read out of the regulation the requirement that a settlement agreement for consistent settlement purposes cannot be based on concessions of nonpartnership items and that a settlement may not be limited to selected items. Where, as here, a settlement agreement contains interrelated provisions which reflect concessions of partnership and nonpartnership items, the temporary regulation provides that such original settlementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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