This bill introduces a new election mechanism for partnerships to resolve ongoing tax disputes concerning certain conservation easement donations . Specifically, it applies to qualified conservation contributions made by partnerships in taxable years ending on or before December 31, 2024, for which a deduction was claimed and where there is an "open matter" with the Internal Revenue Service (IRS). To participate, an electing partnership must file an election statement and remit a settlement amount within a 180-day election period. This settlement amount is calculated based on a "tax component" (the excess of the claimed deduction over a "settlement limitation amount" multiplied by the highest tax rate) and a "penalty component" (determined by applicable penalty rates on the underpayment). Upon an effective election, the allowable deduction for the eligible contribution is limited to the settlement limitation amount , and payment resolves all federal income tax liability, including penalties and interest, attributable to the excess deduction. The parties involved waive their rights to contest these amounts. The settlement limitation amount is generally 2.5 times the relevant basis of partners, or 3.2 times capital contributed for specific types of contributions. The bill includes provisions for common marketing groups , allowing multiple partnerships to aggregate their contributions and elect through a designated partnership, with joint and several liability for the settlement amount. It also addresses situations where some ultimate taxpayer partners do not contribute their share, allowing the IRS to assess those "non-contributing partners" directly. Furthermore, the bill coordinates with existing legal proceedings, allowing withdrawal of pending stipulated decisions but precluding elections if a court decision is final. It permits the IRS to examine elections solely for computational accuracy , with procedures for administrative and judicial review of any determined discrepancies. If an additional amount from a computational adjustment is not paid and not contested, the election becomes void. Finally, the bill amends the Internal Revenue Code to modify the standard for certain qualified conservation contributions and certified historic structures. It replaces the requirement of being "of historic significance to the district" with being a " contributing building ," defining this term based on National Register nominations or certification by the Secretary of the Interior. These amendments apply to specific taxable years and pending proceedings.