- 20 -
v. Commissioner, supra at 301; see Bugaboo Timber Co. v.
Commissioner, supra.
In this case, the authorizing language in the partnership
agreement is almost identical to that in Cambridge Research &
Development Group, granting the general partner the power "to
take any action of any kind and to do anything and everything he
deems necessary in connection" with the partnership business.
Thus, if such a grant of power is not otherwise restricted under
Pennsylvania law, then the partnership agreement in this case
would qualify as a "writing" under section 6229(b)(1)(B).
We have been unable to find a Pennsylvania case on point.
We thus decide the issue as if we were sitting as the highest
court of that State. Commissioner v. Estate of Bosch, 387 U.S.
456, 465 (1967). In enacting the TEFRA provisions, Congress
clearly intended activities involved in a unified partnership-
level tax proceeding to be partnership business. Cambridge
Research & Development Group v. Commissioner, supra at 298. The
power to extend the section 6229(a) period of limitations has
been found to be within the scope of partnership business under
the Uniform Partnership Act (UPA) and the Uniform Limited
Partnership Act (ULPA) as enacted by the States of Alabama,8
8 Ala. Code secs. 10-9A-62, 10-8-49 (Michie 1991); Amesbury
Apartments, Ltd. v. Commissioner, 95 T.C. 227 (1990); see
discussion in Cambridge Research & Development Group v.
Commissioner, 97 T.C. 287, 298 (1991).
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