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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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