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A. Statute of Limitations
Petitioners contend that the section 6229(a) period of
limitations for assessing their partnership items for the 1982
tax year expired on June 30, 1987, several years before
respondent issued the respective notices of deficiency for
1982.15
In general, section 6229(a) provides that the period for
assessing any income tax attributable to partnership items (or
affected items) for a partnership taxable year will not expire
until the later of a date which is 3 years after the partnership
files its information return for the taxable year in question or
the last day for filing such return for such year (without
extensions). This minimum 3-year period may be extended,
suspended, or otherwise modified as provided elsewhere in section
6229. The relevant modifications with respect to petitioners'
cases are in subsections (b), (d), and (f) of section 6229.
Section 6229(b) provides as follows:
(b) EXTENSION BY AGREEMENT.-
(1) IN GENERAL.-The period described in subsection
(a) (including an extension period under this
subsection) may be extended-
(A) with respect to any partner, by an
agreement entered into by the Secretary and
such partner, and
(B) with respect to all partners, by an
agreement entered into by the Secretary and
15 The parties do not dispute that resolution of this issue is
governed by the TEFRA partnership provisions, secs. 6221-6233.
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