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applicable rules are found in section 6229(a), (d), and (g).
Congress enacted section 6229(g) as part of the Tax Reform Act of
1986 (TRA), see Pub. L. 99-514, sec. 1875(d)(1), 100 Stat. 2896,
effective as if included in TEFRA, see TRA sec. 1875(d)(2)(C);
Weiss v. Commissioner, 88 T.C. 1036, 1037 n.1 (1987). Section
6229(a), (d), and (g) provides:
SEC. 6229(a). General Rule.--Except as otherwise
provided in this section, the period for assessing any
tax imposed by subtitle A with respect to any person
which is attributable to any partnership item (or
affected item) for a partnership taxable year shall not
expire before the date which is 3 years after the later
of--
(1) the date on which the partnership
return for such taxable year was filed, or
(2) the last day for filing such return
for such year (determined without regard to
extensions).
* * * * * * *
(d) Suspension When Secretary Makes Administrative
Adjustment.--If notice of a final partnership
administrative adjustment with respect to any taxable
year is mailed to the tax matters partner, the running
of the period specified in subsection (a) (as modified
by other provisions of this section) shall be
suspended--
(1) for the period during which an
action may be brought under section 6226
(and, if a petition is filed under section
6226 with respect to such administrative
adjustment, until the decision of the court
becomes final), and
(2) for 1 year thereafter.
* * * * * * *
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