Settlement Agreement

ID: CCA_2009042715311737 Number: 200922050
Release Date: 5/29/2009
Office: ---
UILC: 6224.01-01
From: ---
Sent: Monday, April 27, 2009 3:31:19 PM
To: ---
Cc: ---
Subject: RE: Procedures For Cases Where Pass-through Partner Wants to Agree and Pay
Del Order 4-19 covers closing agreements for TEFRA partnership items. The courts that have addressed the issue have concluded that section 6224(c) is just a subsection of section 7121 which governs closing agreements that relate to TEFRA partnership items. Furthermore, it is the last sentence of section 6224(c)(1) which makes settlement agreements by pass-though entities binding on the indirect partners.
Del Order 4-19 governs settlement of TEFRA partnership items under section 6224(c), so that is the delegation order that should be used for such settlements.