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causes the conversion of partnership items to non-
partnership items, pursuant to section 6223(e), and is
one of the events described by section 6231(b). To the
contrary, however, it is evident from section 6226(d),
quoted above, that the expiration of the period of
limitations is not one of the events described by section
6231(b) under which partnership items are converted to
nonpartnership items. This is evident from the fact that
the period of limitations on assessment is referred to in
section 6226(d)(1)(B), whereas the events under which
partnership items become nonpartnership items are referred
to in section 6226(d)(1)(A).
Finally, we must say a word about the position of the
other parties to this case, participating partners Wayne H.
Caldwell and John P. Haddock, Jr., and intervening partner
Bill R. Denny. Intervening partner Denny has joined the
pleadings filed by petitioners. He has presented nothing
other than the arguments advanced by petitioners, discussed
above. Participating partner John P. Haddock, Jr., did not
appear at the hearing and has not filed any pleadings.
The brief filed by Mr. Caldwell adopts the arguments
of petitioners, discussed above. In considering those
arguments, we note that it is doubtful that the factual
assertions underlying petitioners' arguments apply to
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