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section 6653(a)(2) equal to 50 percent of the interest due on the
deficiency, an addition to tax of $960 under section 6659, and
increased interest under section 6621(c). After concessions by
petitioners, the issue for decision is whether the period for
assessment under section 6229 was validly extended by the general
partner of the partnership of which petitioner S. Byrne Doyle was
a limited partner.
Background
This case was submitted fully stipulated under Rule 122.
The stipulation of facts is incorporated herein by this reference
and found accordingly. We set forth below only those facts
pertinent to our decision. For general background, see our
opinion in Brown v. Commissioner, T.C. Memo. 1992-379, affd.
without published opinion sub nom. Konenkamp v. Commissioner, 14
F.3d 47 (3d Cir. 1993), where issues for previous years involving
petitioners and the tax aspects of the partnership were
discussed.
At the time of the filing of the petition, petitioners
resided in western Pennsylvania. Petitioners filed a joint 1983
Federal income tax return.
The partnership was organized under the laws of the
Commonwealth of Pennsylvania to engage in racing and breeding
standardbred horses, including Shane T. Hanover, a standardbred
race horse (Shane). Petitioner S. Byrne Doyle was a limited
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