(b)
Elections of the partnership
Any election affecting the computation of taxable income derived from a partnership shall be made by the partnership, except that any election under—
(1)
subsection (b)(5) or (c)(3) of section
108 (relating to income from discharge of indebtedness),
(2)
section
617 (relating to deduction and recapture of certain mining exploration expenditures), or
(3)
section
901 (relating to taxes of foreign countries and possessions of the United States),
shall be made by each partner separately.