Internal Revenue Service, Treasury § 301.6223(g)–1Internal Revenue Service Regulations • March 4th, 2021
Contract Type FiledMarch 4th, 2021decision, or a settlement agreement de- scribed in section 6224(c)(2) with re- spect to the partnership taxable year to which the adjustment relates apply to that partner. If the partner does not make an election in accordance with paragraph (d) of this section, the part- nership items of the partner for the partnership taxable year to which the proceeding relates shall be treated as having become nonpartnership items as of the day on which the Internal Rev- enue Service mails the partner the FPAA.