Bhupindar S. and Rajinder K. Dhillon - Page 5




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          partner's tax liability be determined uniquely but 'the tax                 
          treatment of any partnership item [would] be determined at the              
          partnership level.'"  Maxwell v. Commissioner, 87 T.C. 783, 787             
          (1986) (citing section 6621).                                               
               Pursuant to section 6226(b)(1), any notice partner may file            
          a petition "within 60 days after the close of the 90-day period             
          set forth in subsection (a)".  Subsection (a) of section 6226               
          states in pertinent part:                                                   
                    (a) Petition by Tax Matters Partner.--Within 90 days              
               after the day on which a notice of a final partnership                 
               administrative adjustment is mailed to the tax matters                 
               partner, the tax matters partner may file a petition for a             
               readjustment of the partnership items for such taxable year            
               with--                                                                 
                         (1) the Tax Court,                                           
          Section 6231(a)(8) defines a "notice partner" as a "partner who,            
          at the time in question, would be entitled to notice under                  
          subsection (a) of section 6223 (determined without regard to                
          subsections (b)(2) and (e)(1)(B) thereof)."  Section 6223(a)                
          provides:                                                                   
                    (a) Secretary Must Give Partners Notice of Beginning              
               and Completion of Administrative Proceedings.--The Secretary           
               shall mail to each partner whose name and address is                   
               furnished to the Secretary notice of--                                 
                         (1)  the beginning of an administrative proceeding           
                    at the partnership level with respect to a partnership            
                    item, and                                                         
                         (2)  the final partnership administrative                    
                    adjustment resulting from such proceeding.                        







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