- 2 -
Five of the seven petitioners in these seven
consolidated cases have raised the affirmative defense
of statute of limitations. Those five petitioners
argue that the notices of final partnership
administrative adjustment in question were not timely
because they were issued after expiration of the
sec. 6229(a), I.R.C., assessment period.
Held: In all five cases, either a valid Form 872-
P, Consent to Extend the Time to Assess Tax
Attributable to Items of a Partnership, was signed by
the tax matters partner or another person authorized in
writing by the partnership to enter into such an
agreement, or no valid partnership return was filed
that would fix the time to assess tax under sec.
6229(a), I.R.C.
Steven Mather and Kenneth Barish, for petitioners.
William H. Quealy, Jr., Alice M. Harbutte, Henry T. Schafer,
Guy Glaser, Laurel Robinson, and Ann Durning, for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011