- 37 -
legislative history to support such a theory. Indeed, in
Crawford v. Commissioner, 97 T.C. 302 (1991), we explicitly held
that section 183(e)(4) "modifies" the normal 3-year period of
limitations in section 6501(a) with respect to a section 183
activity for which an election was made. As a result, we held
that a written agreement to extend the period of limitations
pursuant to section 6501(c)(4) that was executed after the normal
3-year period, but before expiration of the period as modified by
section 183(e)(4), was effective to extend the period of
limitations for the limited purpose of assessing deficiencies
attributable to the section 183 activity. Our holding that
section 183(e)(4) modified the normal 3-year period of
limitations in which a section 6501(c)(4) agreement can be
executed is clearly inconsistent with any suggestion that a
section 183(e) election is an agreement within the meaning of
section 6501(c)(4). The last sentence of section 6501(c)(4)
explicitly provides that a written agreement to extend the period
of limitations may be extended by "subsequent agreements". In
Crawford v. Commissioner, supra, we clearly did not consider this
provision regarding "subsequent agreements" to be applicable
because we did not view the previous section 183(e) election as
an agreement. A taxpayer's election pursuant to section 183(e)
is simply a unilateral act that has statutory consequences; i.e.,
it allows the taxpayer additional time to qualify for a
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