Settlement Agreement

ID: CCA_2010080908461637 Number: 201035017
Release Date: 9/3/2010
Office: ---
UILC: 6224.01-01
From: ---
Sent: Monday, August 09, 2010 8:46:21 AM
To: ---
Cc: ---
Subject: RE:
Under section 6224(c)(1)(last sentence), a settlement by a pass-thru partner binds indirect partners to the settlement of partnership items. The problem is that the Form 870-LT (unlike the PT version of the form) has a second part separately executed with respect to affected items. A pas-thru partner cannot bind indirect partners as to partner-level items on Part II of this form.
So you are correct that the indirect partners should sign this form since the trust cannot sign Part II for them.