- 40 - year thereafter. Finally, section 6229(f) provides that, if one or more of the events described in section 6231(b) take place, under which partnership items are converted into nonpartnership items, and if the event takes place before the expiration of the period of limitations on assessment, then the period of limitations with respect to the tax on those items will not expire before 1 year after the conversion. In substance, petitioners argue that their petition for readjustment must be dismissed and respondent must be foreclosed from assessing any tax attributable to the subject partnership items on two grounds. As mentioned earlier, the first ground is that respondent failed to mail the notice of FPAA to the tax matters partner. We have disposed of that contention above. The second ground is that respondent failed to give petitioners the notice required by section 6223(a)(2) within the time required by section 6223(d)(2), with the result that their partnership items for 1983 became nonpartnership items, pursuant to the remedy provision set out in section 6223(e), and cannot be adjusted in this proceeding at the partnership level. In support of their second ground, petitioners assert that the notice of FPAA was never mailed to the notice partners as required by section 6223(a)(2). In furtherPage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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