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intent. According to petitioners' argument, summarized
above, the person who prepared the consent on behalf of
respondent thought that Mr. Brody held an interest in
Thunderbird directly and did not know that Mr. Brody held
his interest in Thunderbird through BDB. Petitioners
contend that if respondent's agent had known, then he
"would have asked all of the other partners of BDB to
execute waivers". Petitioners complain that "if this
Court makes this deficiency applicable to Mr. Brody his
return will then be inconsistent with the return of BDB
and inconsistent with the return of all the other partners
of the BDB partnership."
Accepting petitioners' factual allegations as true for
purposes of this discussion, we agree that respondent's
agent would have asked all partners of BDB, including
petitioners, to execute waivers of the period of
limitations on assessment and collection. Prior to the
enactment of the uniform audit procedures for partner-
ships in sections 6221 through 6233, the Commissioner
was required to obtain a consent for extension of the
period of limitations from each of the partners, not
the partnership. See Staff of Joint Comm. on Taxation,
General Explanation of the Revenue Provisions of the Tax
Equity and Fiscal Responsibility Act of 1982, at 267 (J.
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