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Mr. Caldwell. First, it is undisputed that Mr. Caldwell
signed an open-ended extension of the period of limitations
on assessment on Form 872-O. Even if Mr. Caldwell was not
the tax matters partner or authorized by the partnership to
enter into such an agreement, as petitioners contend, the
agreement on Form 872-O executed by Mr. Caldwell would seem
to have the effect of extending the period of limitations
in Mr. Caldwell's individual case. See sec. 6229(b)(1)(A).
Mr. Caldwell does not address this issue. Second, it is
undisputed that the notice of FPAA was sent to Mr. Caldwell
and was received by him before the expiration of the period
of limitations, as extended by the agreement on Form 872-O.
In order to bolster his argument that the period of
limitations had expired, Mr. Caldwell argues that the
agreement to extend the period of limitations on Form 872-O
was not valid because the Appeals officer who signed the
agreement on behalf of respondent, Mr. Norstrud, did not
have authority to do so. We need not resolve this issue.
As discussed above, it is unnecessary to find whether the
period of limitations had actually expired before the
notice of FPAA was mailed to notice partners. This is
because we reject petitioners' contention that the period
of limitations on assessment is incorporated within the
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