- 37 - deficiency at issue in these cases to petitioners on July 19 and 20, 1990.18 Petitioners argue that the Consents were not effective to extend respondent's time to make the adjustments at the partnership level to which any deficiency or addition to tax could be attributed. We disagree. Section 6229(b)(2) provides that any agreement under section 6501(c)(4) shall apply with respect to the limitations period described in subsection (a) only if such agreement expressly provides that such agreement applies to tax attributable to partnership items. The Forms 872-A executed by the Sanns and Addington contained the following restrictive language: (5) The amount of any deficiency assessment is to be limited to that resulting from any adjustments to (a) items affected by the carryover or continuing tax effect caused by adjustments to any prior tax return; (b) the taxpayer's distributive share of any item of income, gain, loss, deduction, or credit of, or distribution from JABRILACH RECYCLING #13-3133726 (c) the tax basis of the taxpayer's interest(s) in the aforementioned partnership(s) or organization(s) treated by the taxpayer(s) as a partnership; and (d); any gain or loss (or the character or timing thereof) realized upon the sale or exchange, abandonment, or other disposition of taxpayer's interest in such partnership(s) or organization(s) treated by the taxpayer as a partnership; including any consequential changes to other items based on such adjustment. 18 The notices of deficiency for the 1982 tax year were issued to Addington and the Sanns on July 19, 1990, and to Cohn on July 20, 1990.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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