[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6229(f)-1]

[Page 180]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                               Assessment
 
Sec. 301.6229(f)-1  Special rule for partial settlement agreements.

    (a) In general. If a partner enters into a settlement agreement with 
the Internal Revenue Service with respect to the treatment of some of 
the partnership items or partnership-level determinations of any 
penalty, addition to tax, or additional amount in dispute for a 
partnership taxable year, but one or more other partnership items or 
determinations remain in dispute, the period of limitations for 
assessing any tax attributable to the settled items shall be determined 
as if such agreement had not been entered into.
    (b) Other items remaining in dispute. Pursuant to section 6226(c), a 
partner is a party to a partnership-level judicial proceeding with 
respect to partnership items and partnership-level determinations of 
penalties, additions to tax or additional amounts. When a partner 
settles partnership items, the settled partnership items convert to 
nonpartnership items under section 6231(b)(1)(C) and will not be subject 
to any future or pending partnership-level proceeding pursuant to 
section 6226(d)(1). The remaining unsettled partnership items, as well 
as any unsettled penalty, addition to tax, or additional amount that 
relates to an adjustment to a partnership item (regardless of whether 
the partnership item to which it relates has been settled), however, 
will remain subject to determination under partnership-level 
administrative and judicial procedures. Consequently, any remaining 
unsettled items, including any unsettled penalty, addition to tax, or 
additional amount that relates to an adjustment to a partnership item, 
will be deemed to remain in dispute. Thus, the period for assessing any 
tax attributable to the settled items will be governed by the period for 
assessing any tax attributable to the remaining unsettled items.
    (c) Effective date. This section is applicable to partnership 
taxable years beginning on or after October 4, 2001. For years beginning 
prior to October 4, 2001, see Sec. 301.6229(f)-1T contained in 26 CFR 
part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50555, Oct. 4, 2001]