- 6 - minimum period may be extended, suspended, or otherwise modified as provided in section 6229. As pertinent herein, section 6229(d) provides that the running of the period of limitations specified in subsection (a) is suspended from the date on which the notice of final partnership administrative adjustment is mailed to the partnership's TMP through the date on which the decision of this Court becomes final and for 1 year thereafter. Pursuant to sections 7481(a) and 7483, if a timely notice of appeal is not filed, the decision of this Court becomes final 90 days after the decision is entered. In this regard, there is no dispute that the period for assessing the additions to tax in dispute expired no earlier than October 19, 1995; i.e., 1 year and 90 days from the entry of decision in the Taylor case. Section 6503(a)(1) provides that the running of the period of limitations on assessment and collection will be tolled upon the mailing of a notice of deficiency under section 6212(a). In the present case, respondent mailed the affected items notice of deficiency on August 28, 1995, nearly 2 months before the expiration of the period for assessment and collection under section 6229. Accordingly, the only issue is whether the notice of deficiency is valid. Petitioner claims that the notice was not mailed to his last known address and is therefore invalid. A notice of deficiency is valid if the taxpayer actually receives the notice and thereafter files a timely petition in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011