- 51 - 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 toPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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