I have that same board (Gigabyte GA-K8NNXP-940) with an Opteron 144. The combination of the Sledgehammer core and the ECC RAM makes overclocking a bit of a pain, but it is by no means impossible.
I am currently using the F3 BIOS, though there is an F4 BIOS that is in BETA. Because my Opteron is locked, FSB is my only choice to go up. However, I have heard reports that that changing the multiplier on this particular board can cause problems, so to cover all your bases, you should try both the multiplier and a higher FSB.
If you are changing the multiplier, no other bus speeds are affected, so other than adding a bit of voltage to the processor, nothing else should need adjusting.
When changing the FSB, you will need to account for the increased bus speed. Remember that because this is the old NForce3 Pro chipset, the default HTT is 3x (for 600Mhz, not 800 or 1000 like the newer versions). So, to overclock, set it lower (2.5x should be fine). You may also have to reduce the RAM to DDR333 so that when you overclock, it doesn't go too far above DDR400.
Remember, even though this board locks down the PCI and AGP busses, it DOES NOT lock down the onboard components. The biggest offender is the onboard Silicon Image SATA controller; it HATES high bus speeds, so disable it if you plan to raise the FSB above around 225. If you are using a SATA drive, buy a PCI controller for it ($20), and you'll be good to go.
Try overclocking with Gigabyte's Easytune4 utility, it tends to be stable at higher bus speeds than a BIOS overclock (I have no idea why....). And remember to hit Ctrl+F1 in the BIOS to access the hidden overclocking menu with memory and HTT settings.
Keep in mind the limitations of your processor. The FX-55 (2.6 Ghz) was the fastest AMD's 130nm chips ever went, so don't expect too much higher on air cooling (though 2.7 might be possible with water).