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after the later of (1) the date the partnership return for such
year was filed or (2) the last day for filing such return for
such year (without regard to extensions).3 However, section
6229(d) provides that the mailing of a final partnership
administrative adjustment suspends the running of the 3-year
limitations period for the period during which an action may be
brought under section 6226 (and, if an action is brought, until
the decision of the court has become final) and for 1 year
thereafter.
The stipulation of facts includes a copy of the decision
entered regarding Barbados, which is dated December 6, 1993.
Under section 6229(d)(2), the running of the 3-year period of
limitations for assessing a deficiency attributable to a 1982
partnership item was suspended for 1 year after the date the
decision entered on December 6, 1993, became final. The decision
became final no earlier than March 6, 1994 (90 days after it was
entered). Secs. 7481(a)(1), 7483. The notice of deficiency was
issued to petitioner on February 3, 1995. Consequently, the
notice of deficiency relating to the affected items (the
additions to tax) was timely issued.
2. Negligence
Section 6653(a)(1) imposes an addition to tax if any portion
of an underpayment is due to negligence or intentional disregard
3The additions to tax determined by respondent are affected
items. Sec. 301.6231(a)(5)-1T(d), Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987).
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