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E loss attributable to her investment as a limited partner in Barbados.
OPINION
Respondent's determinations, contained in the notice of
deficiency, are presumed correct, and petitioner bears the burden
of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933).
1. Statute of Limitations
The notice of deficiency was issued to petitioner on
February 3, 1995, for additions to tax associated with
petitioner's distributive share of partnership items. Respondent
determined that petitioner is liable for additions to tax
provided in sections 6653(a) and 6661(a). Petitioner contends
that she is not liable because, having filed her 1982 Federal
income tax return on October 19, 1983, the 3-year statutory
period of limitations provided in section 6501 expired before
issuance of the notice of deficiency.
Under the general rule set forth in section 6501, the
Secretary is required to assess the tax within 3 years after the
taxpayer's return is filed. Sec. 6501(a). In the case of the
tax imposed on partnership items, however, section 6229 sets
forth special rules to extend the period of limitations
prescribed by section 6501. See sec. 6501(o).
Section 6229(a) provides that the period for assessing
income tax attributable to a partnership item (or affected item)
for a partnership taxable year shall not expire before 3 years
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