- 5 - Recycling Associates, DL & K Associates, A Partner Other Than the Tax Matters Partner v. Commissioner, docket No. 10184-88 (the Taylor case) was commenced in this Court on behalf of Taylor. On July 21, 1994, the Court entered decision in the Taylor case pursuant to the Commissioner's motion for entry of decision under Rule 248(b). All deductions and credits claimed by Taylor in connection with its plastics recycling activities were disallowed. Thereafter, on August 28, 1995, respondent issued the affected items notice of deficiency for 1982 determining additions to tax under sections 6653(a)(1) and (2), and 6659. Petitioner appealed from the notice and filed his petition with this Court on November 22, 1995. OPINION 1. Tolling of the Period of Limitations Petitioner claims that the period of limitations for assessment and collection for the additions to tax in dispute has expired because of respondent's failure to issue a valid notice of deficiency. We disagree. Pursuant to the general rule of section 6229(a), 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 that 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. The 3-yearPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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