524
Opinion of the Court
return does not contain all of the information necessary to compute a shareholder's taxes and thus should not be regarded as triggering the period of assessment. Cf. Automobile Club of Mich. v. Commissioner, 353 U. S. 180, 188. The statutory evidence and policy considerations proffered by Bufferd offer no basis for questioning this conclusion. Pp. 526-533. 952 F. 2d 675, affirmed.
White, J., delivered the opinion for a unanimous Court.
Stuart J. Filler, by appointment of the Court, 506 U. S. 809, argued the cause for petitioner. With him on the briefs were Toni Robinson and Mary Ferrari.
Kent L. Jones argued the cause for respondent. With him on the brief were Solicitor General Starr, Acting Assistant Attorney General Bruton, Deputy Solicitor General Wallace, Ann B. Durney, and Janet Kay Jones.*
Justice White delivered the opinion of the Court.
On his 1979 income tax return, petitioner, a shareholder in a Subchapter S corporation, claimed as "pass-through" items portions of a deduction and a tax credit reported on the corporation's return. The question presented is whether the 3-year period in which the Internal Revenue Service is permitted to assess petitioner's tax liability runs from the filing date of the individual return or the corporate return. We conclude with the Tax Court and the Court of Appeals for the Second Circuit that the relevant date is that on which petitioner's return was filed.
I
Subchapter S of the Internal Revenue Code, 26 U. S. C. §§ 1361-1379, was enacted in 1958 to eliminate tax disadvantages that might dissuade small businesses from adopting
*Briefs of amici curiae urging reversal were filed for Arthur H. Boelter and John J. White, Jr., pro se; and for Charles T. Green et al. by Robert I. White.
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