Rule 7. Settlement Agreements

(a) Consent by the Tax Matters Partner
to Entry of Decision. A stipulation consenting to
entry of decision executed by the tax matters
partner and filed with the court shall bind all
parties. The signature of the tax matters partner
constitutes a certificate by the tax matters partner
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that no party objects to entry of the decision. See
Rule 10 below.
(b) Settlement Agreements Entered
Into by All Participating Partners or No
Objection by Participating Partners.
(1) After expiration of the time
within which to file a notice of election to
intervene or to participate under Rule 4(a)
or (b) above, the United States shall move
for entry of decision and shall submit a
proposed form of decision with such
motion, if
(A) all of the participating
partners have entered into a
settlement agreement with
defendant, or all of such partners do
not object to the granting of
defendant's motion for entry of
decision, and
(B) the tax matters partner (if a
participating partner) agrees to the
proposed decision in the case but
does not certify that no party objects
to the granting of defendant's motion
for entry of decision.
(2) Within 3 days after the date on
which the defendant's motion for entry of
decision is filed with the court, defendant
shall serve on the tax matters partner a
certificate showing the date on which the
defendant's motion was filed with the
court.
(3) Within 3 days after receiving
defendant's certificate, the tax matters
partner shall serve on all other parties to
the action, other than the participating
partners, copies of defendant's motion for
entry of decision, the proposed decision,
and defendant's certificate showing the
date on which defendant's motion was
filed with the court, as well as a copy of
this paragraph of Rule 7.
(4) If any party objects to the
granting of the defendant's motion for
entry of decision, then that party shall,
within 60 days after the date on which
defendant's motion was filed with the
court, file a motion for leave to file a
notice of election to intervene or to
participate, accompanied by a separate
notice of election to intervene or to
participate, as the case may be. If no such
motion is filed with the court within such
period, or if the court should deny such
motion, then the court may enter the
proposed decision as its decision in the
partnership action. See Code Sections
6226(f) and 6228(a)(5).
(c) Other Settlement Agreements. If a
settlement agreement is not within the scope of
subdivision (b) above, then
(1) in the case of a participating
partner, defendant shall promptly file
with the court a notice of settlement
agreement that identifies the participating
partner or partners who have entered into
the settlement agreement; and
(2) in the case of any partner who
enters into a settlement agreement,
defendant shall, within 7 days after the
settlement agreement is executed by both
the partner and defendant, serve on the
tax matters partner a statement which sets
forth
(A) the identity of the party or
parties to the settlement agreement
and the date of the agreement;
(B) the year or years to which
the settlement agreement relates;
and
(C) the terms of settlement as
to each partnership item and the
allocation of such items among the
partners.
Within 7 days after receiving the
statement required by this subdivision,
the tax matters partner shall serve a copy
of the statement on all parties to the
action.