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6224(c)(2) reads in pertinent part and with exceptions not
applicable herein, as follows:
SEC. 6224(c)(2). Other partners have right to enter
into consistent agreements.--If the Secretary enters into a
settlement agreement with any partner with respect to
partnership items for any partnership taxable year, the
Secretary shall offer to any other partner who so requests
settlement terms for the partnership taxable year which are
consistent with those contained in such settlement agreement.
* * * this paragraph shall apply with respect to a settlement
agreement entered into with a partner before notice of a
final partnership administrative adjustment is mailed to the
tax matters partner only if such other partner makes the
request before the expiration of 150 days after the day on
which such notice is mailed to the tax matters partner.
Where, after issuance of the related FPAA to the TMP, a
settlement agreement is entered into with a partner, section
301.6224(c)-3T(c)(3), Temporary Proced. & Admin. Regs., 52 Fed.
Reg. 6787 (Mar. 5, 1987), provides that other partners who wish to
enter into consistent settlement agreements must submit a request
therefor to respondent within either 150 days after the FPAA was
issued or 60 days after the day on which the prior settlement was
entered into, whichever is later. Section 301.6224(c)-3T,
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6787 (Mar. 5,
1987), reads in part as follows:
(a) In general. If the Service enters into a settlement
agreement with any partner with respect to partnership items,
the Service shall offer to any other partner who so requests
in accordance with paragraph (c) of this section settlement
terms which are consistent with those contained in the
settlement agreement entered into.
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