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Page 2 of the exhibit summarizes Tax Court Rule 248(c) and includes the documents and signatures that are required.Rule 248(c): A participating partner agrees to the settlement. A notice that a settlement of agreement or a consistent agreement has been secured is filed with the court. It requires the signature of local counsel.If a participating partner or non-participating partner agrees to the settlement, a Form 870-P(AD) or Form 870-PT(AD) must be signed by the partner and the commissioner.Within 7 days of the acceptance of the settlement, the commissioner serves a statement on the TMP that includes: the identity of the party or parties, the tax year(s), the terms of the settlement, and the date that the settlement was entered into.Within 7 days of receipt, the TMP will serve a copy of the statement on all parties who have not settled.All parties who have not accepted the settlement may request consistent agreement within 60 days of the settlement. If any parties agree, a Form 870-P(AD) or Form 870-PT(AD) is signed marked Consistent Agreement. The agreement is signed by the party that agrees and on behalf of the commissioner.