Contents of statement. Except as otherwise provided in instructions to the taxpayer from the Internal Rev- enue Service, the written statement described in paragraph (c)(1) of this section shall— (i) Identify the statement as a re- quest for consistent settlement terms under section 6224(c)(2); (ii) Contain the name, address, and taxpayer identification number of the partnership and of the partner request- ing the settlement offer (and, in the case of an indirect partner, of the pass- thru partner through which the indi- rect partner holds an interest); (iii) Identify the earlier agreement to which the request refers; and (iv) Be signed by the partner making the request.
Appears in 2 contracts
Sources: Settlement Agreement, Settlement Agreement