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the tax matters partner (or any other person
authorized by the partnership in writing to
enter into such an agreement),
before the expiration of such period.
(2) COORDINATION WITH SECTION 6501(c)(4).--Any
agreement under section 6501(c)(4) shall apply with
respect to the period described in subsection (a) only
if the agreement expressly provides that such agreement
applies to tax attributable to partnership items.
Section 6229(d) provides that the running of the limitations
period is suspended from the date when the notice of Final
Partnership Administrative Adjustment (FPAA) is mailed to the
partnership's TMP for (1) the period during which an action may
be brought for judicial review of the FPAA, and if such an action
is brought, until the decision of the court becomes final, and
(2) for 1 year thereafter. The period during which an action may
be brought is generally 150 days. Sec. 6226(a) and (b); see sec.
7503.
Section 6229(f) provides that if partnership items become
nonpartnership items before the expiration of the limitations
period otherwise provided, then the limitations period shall not
expire before the date that is 1 year after the date on which
partnership items become nonpartnership items.
Foam filed its partnership return for the 1982 tax year on
March 16, 1983. Therefore, the limitations period was initially
set to expire on April 15, 1986. Sec. 6229(a). However, on
November 5, 1985, one of the attorneys-in-fact for Foam, Shaye
Jacobson (Jacobson), executed a Form 872-P, Consent to Extend the
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