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requesting partner must file his request for a consistent
settlement offer with the Internal Revenue Service office that
entered into the settlement on or before (i) the 150th day after
the day on which the FPAA was mailed to the TMP, or (ii) the 60th
day after the day on which the settlement was entered into,
whichever is later. Id. The settlements occurred in 1991.
Petitioners’ first request for consistent settlement appears to
have been incorporated in the petition in docket No. 16247-99S,
filed with this Court on October 19, 1999. That request was not
made as or when required by section 301.6224(c)-3T(c), Temporary
Proced. & Admin. Regs., supra. Because petitioners failed to
meet the requirements of section 6224(c)(2), respondent was not
obligated to make petitioners a consistent settlement offer.
Petitioners allege that because respondent failed to notify
them of other settlement agreements, they were prevented from
making a proper and timely request under section 6224(c)(2).
Petitioners therefore contend respondent’s failure to so notify
them renders the relief provided in section 6224(c)(2)
meaningless unless respondent is now obligated to extend a
settlement offer consistent with the terms of those prior
settlement agreements. Respondent disagrees, contending that the
Code obligates Jojoba’s TMP, not respondent, to notify
petitioners of any settlement agreement that respondent entered
into with respect to Jojoba. We agree with respondent. As we
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