- 16 -
Comm. Print 1982). However, even assuming that
respondent's agent did not know that Mr. Brody held his
interest in Thunderbird through BDB, there is no reason to
believe that respondent would have acted differently as to
petitioners. Nothing attached to petitioners' cross-motion
for summary judgment suggests that respondent would not
have sought to obtain a waiver of the period of limitation
from petitioners or that respondent would have sought a
waiver from petitioners on different terms.
Furthermore, we agree with petitioners that if the
period of limitations remains open with respect to
petitioners' 1978 return but not with respect to other
partners of BDB, then "inconsistent results" could follow.
In fact, that is one of the problems which led to the
enactment of the unified partnership procedures in sec-
tions 6221 through 6233. See id. at 268 ("Inconsistent
results could be obtained for different partners with
respect to the same item."). However, the possibility of
any such inconsistent results does not mean that respondent
and petitioners failed to reach an "agreement" to extend
the period of limitations with respect to the losses from
Thunderbird reported on petitioners' 1978 return or that
there is any reason not to give effect to that agreement.
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