Page:United States Statutes at Large Volume 111 Part 1.djvu/1049

 PUBLIC LAW 105-34—AUG. 5, 1997 111 STAT. 1025 (2) by moving the text of such subsection 2 ems to the right, ana (3) by adding at the end the following new paragraph: "(2) SPECIAL RULE FOR PARTL\L 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 26 USC 6229 shall apply to settlements entered into after the date of the enact- note. ment of this Act. SEC. 1236. EXTENSION OF TIME FOR FILING A REQUEST FOR ADMINIS- TRATIVE ADJUSTMENT. (a) IN GENERAL.— Section 6227 (relating to administrative adjustment requests) is amended by redesignating subsections (b) and (c) as subsections (c) and (d), respectively, and by inserting after subsection (a) the following new subsection: "(b) SPECIAL RULE IN CASE OF EXTENSION OF PERIOD OF LIMITA- TIONS UNDER SECTION 6229. —The period prescribed by subsection (a)(1) for filing of a request for an administrative adjustment shall be extended— "(1) for the period within which an assessment may be made pursuant to an agreement (or any extension thereof) under section 6229(b), and "(2) for 6 months thereafter.". (b) EFFECTIVE DATE. —The amendment made by this section 26 USC 6227 shall take effect as if included in the amendments made by section note. 402 of the Tax Equity and Fiscal Responsibility Act of 1982. SEC. 1237. AVAILABILITY OF INNOCENT SPOUSE RELIEF IN CONTEXT OF PARTNERSHIP PROCEEDINGS. (a) IN GENERAL.— Subsection (a) of section 6230 is amended by adding at the end the following new paragraph: "(3) SPECIAL RULE IN CASE OF ASSERTION BY PARTNER'S SPOUSE OF INNOCENT SPOUSE RELIEF.— "(A) Notwithstanding section 6404(b), if the spouse of a partner asserts that section 6013(e) applies with respect to a liability that is attributable to any adjustment to a partnership item, then such spouse may file with the Secretary within 60 days after the notice of computational adjustment is mailed to the spouse a request for abatement of the assessment specified in such notice. Upon receipt of such request, the Secretary shall abate the assessment. Any reassessment of the tax with respect to which an abatement is made under this subparagraph shall be subject to the deficiency procedures prescribed by subchapter B. The period for making any such reassessment shall not expire before the expiration of 60 days after the date of such abatement. "(B) If the spouse files a petition with the Tax Court pursuant to section 6213 with respect to the request for abatement described in subparagraph (A), the Tax Court shall only have jurisdiction pursuant to this section to determine whether the requirements of section 6013(e)

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