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nonpartnership items. Death of the partner is not listed among
the events.
The statute of limitations for partnership items under TEFRA
is set forth in section 6229. Section 6229 provides that the
period for assessment is 3 years from the later of (1) the date
on which the partnership return for the taxable year was filed or
(2) the last day for filing such return for such year (determined
without regard to extensions). Sec. 6229(a). However, under
section 6229(d), if a notice of FPAA is mailed to the tax matters
partner:
the running of the period specified in subsection (a)
(as modified by other provisions of this section) shall
be suspended--
(1) for the period during which an action may
be brought under section 6226 (and, if an action
with respect to such administrative adjustment is
brought during such period, until the decision of
the court in such action becomes final), and
(2) for 1 year thereafter.
Section 6226 states:
(a) Petition by Tax Matters Partner.--Within
90 days after the day on which a notice of a final
partnership administrative adjustment is mailed to the
tax matters partner, the tax matters partner may file a
petition for a readjustment of the partnership items
for such taxable year with--
(1) the Tax Court * * *
The statute of limitations for assessment of transferee liability
under section 6901(c) is as follows:
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Last modified: May 25, 2011