special enforcement matters
(11) Treatment of special enforcement matters (A) In general In the case of partnership-related items which involve special enforcement matters, the Secretary may prescribe regulations pursuant to which— (i) this subchapter (or any portion thereof) does not apply to such items, and (ii) such items are subject to such special rules (including rules related to assessment and collection) as the Secretary determines to be necessary for the effective and efficient enforcement of this title. (B) Special enforcement matters For purposes of subparagraph (A), the term “special enforcement matters” means— (i) failure to comply with the requirements of section 6226(b)(4)(A)(ii), (ii) 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), (iii) criminal investigations, (iv) indirect methods of proof of income, (v) foreign partners or partnerships, and (vi) other matters that the Secretary determines by regulation present special enforcement considerations.