26 CFR § 301.6231(c)-3 - Limitation on applicability of §§ 301.6231(c)–4 through 301.6231(c)–8.
(a) In general. A provision of §§ 301.6231(c)–4 through 301.6231(c)–8 shall not apply with respect to partnership items arising in a partnership taxable year if, as of the date on which those items would otherwise begin to be treated as nonpartnership items under that provision—
(1) A notice of final partnership administrative adjustment with respect to those items has been mailed to the tax matters partner; and
(2) Either—
(i) The period during which an action with respect to that final partnership administrative adjustment may be brought under section 6226 has expired and no such action has been brought; or
(ii) The decision of the court in an action brought under section 6226 with respect to that final partnership administrative adjustment has become final.
(b) Effective date. This section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6231(c)–3T contained in 26 CFR part 1, revised April 1, 2001.