Cascade Partnership, James M. and Margaret C. Costello, Tax Matters Partner - Page 9

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          item.  Section 6229(b) permits extension of the 3-year period by            
          means of agreement.  Subparagraph (A) of section 6229(b)(1)                 
          permits an individual partner to extend the assessment period               
          with respect to that partner.  Subparagraph (B) of section                  
          6229(b)(1) provides for extensions applicable to all partners by            
          means of agreements entered into with the TMP or any other                  
          partner who is authorized in writing by the partnership to enter            
          into an extension agreement.                                                
               At the time (early 1986) that Costello executed the Form               
          872-O, no regulations had been issued concerning the provisions             
          of section 6229.  Temporary procedural regulations were adopted             
          providing specific requirements for the written authorization for           
          persons, other than a TMP, to execute a consent binding on all              
          partners after the 1986 consent to extend the assessment period             
          had been executed.  See sec. 301.6229(b)-1T, Temporary Proced. &            
          Admin. Regs., 52 Fed. Reg. 6789 (Mar. 5, 1987).  Under the                  
          temporary regulation, the statement or writing is to contain the            
          identity of the partnership and the person being authorized,                
          along with their address and taxpayer identification number.  In            
          addition, the particular taxable year(s) of the partnership was             
          to be identified, and the writing was to be signed by all persons           
          who were general partners at any time during the effective year             
          or years of the authorization.                                              
               In Amesbury Apartments, Ltd. v. Commissioner, 95 T.C. 227,             
          242 (1990), we held that the taxpayer’s reliance on this                    




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