- 6 - respect to AVA, AVF, DV-85, HFA-II,3 and TFV, a valid Form 872-P, Consent to Extend the Time to Assess Tax Attributable to Items of Partnership (Form 872-P), was executed by a person with the authority to bind the partnership pursuant to section 6229(b)(1)(B). For convenience and clarity, we set forth separately our findings of fact and opinion with respect to each of the five partnerships (sometimes, collectively, the partnerships). We precede that discussion, however, with a discussion of certain provisions of law applicable generally with respect to the partnerships. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. II. Generally Applicable Provisions of Law A. Period of Limitations Applicable to Assessment of Partnership Items These consolidated cases arise in connection with respondent’s determination of certain partnership items. See secs. 6221, 6226(a) and (b). Section 6229(a) provides that the period for assessing any Federal income tax attributable to any 3 For HFA-II, the issues are in the alternative because, if we find that no valid partnership return was filed for 1985, which, if filed, would have fixed the period for assessing any tax, we need not address whether there was a valid consent to extend such period.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