EXCLUSION OF PARTIAL SETTLEMENTS FROM 1-YEAR LIMITATION ON ASSESSMENT.

SEC. 1235. EXCLUSION OF PARTIAL SETTLEMENTS FROM 1-YEAR LIMITATION ON ASSESSMENT. (a) In General.—Subsection (f) of section 6229 (relating to items becoming nonpartnership items) is amended— (1) by striking “(f) Items Becoming Nonpartnership Items.—If” and inserting the following: “(f) Special Rules.— “(1) Items becoming nonpartnership items.—If”,111 STAT. 1025 (2) by moving the text of such subsection 2 ems to the right, and (3) by adding at the end the following new paragraph: “(2) Special rule for partial settlement agreements.—If a partner enters into a settlement agreement with the Secretary with respect to the treatment of some of the partnership items in dispute for a partnership taxable year but other partnership items for such year 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) Effective Date.—The amendment made by this section shall apply to settlements entered into after the date of the enactment of this Act.