PUBLIC LAW 97-248—SEPT. 3, 1982 "(i) has complied with subparagraph (B) of section 6222(b)(1) (relating to notification of inconsistent treatment) with respect to one or more of such items, and "(ii) has not, as of the date on which the Secretary mails the notice, filed a request for administrative adjustments which would make the partner's treatment of the item or items with respect to which the partner complied with subparagraph (B) of section 6222(b)(1) consistent with the treatment of such item or items on the partnership return, or "(B)(i) such partner has filed a request under section 6227(b) for administrative adjustment of one or more of such items, and "(ii) the adjustments requested would not make such partner's treatment of such items consistent with the treatment of such items on the partnership return. "(3) NOTICE MUST BE MAILED BEFORE BEGINNING OF PARTNER-
SHIP PROCEEDING.—Any notice to a partner under subparagraph (A) of paragraph (1) with respect to partnership items for a partnership taxable year shall be mailed before the day on which the Secretary mails to the tax matters partner a notice of the beginning of an administrative proceeding at the partnership level with respect to such items. "(c) REGULATIONS WITH RESPECT TO CERTAIN SPECIAL ENFORCEMENT AREAS.— "(1) APPLICABILITY OF SUBSECTION.—This subsection applies in
the case of— "(A) assessments under section 6851 (relating to termination assessments of income tax) or section 6861 (relating to jeopardy assessments of income, estate, gift, and certain excise taxes), "(B) criminal investigations, "(C) indirect methods of proof of income, "(D) foreign partnerships, and "(E) other areas that the Secretary determines by regulation to present special enforcement considerations. "(2) ITEMS MAY BE TREATED AS NONPARTNERSHIP ITEMS.—To the
extent that the Secretary determines and provides by regulations that to treat items as partnership items will interfere with the effective and efficient enforcement of this title in any case described in paragraph (1), such items shall be treated as nonpartnership items for purposes of this subchapter. "(3) SPECIAL RULES.—The Secretary may prescribe by regulation such special rules as the Secretary determines to be necessary to achieve the purposes of this subchapter in any case described in paragraph (1). "(d) TIME FOR DETERMINING PARTNER'S PROFITS INTEREST IN PARTNERSHIP.—
"(1) IN GENERAL.—For purposes of section 6223(b) (relating to special rules for partnerships with more than 100 partners) and paragraph (11) of subsection (a) (relating to 5-percent group), the interest of a partner in the profits of a partnership for a partnership taxable year shall be determined— "(A) in the case of a partner whose entire interest in the partnership is liquidated, sold, or exchanged during such partnership taxable year, as of the moment immediately before such liquidation, sale, or exchange, or
96 STAT. 665
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