- 7 - partnership item for the partnership’s taxable year shall not expire before 3 years after the later of (1) the date on which the partnership return for such taxable year was filed, or (2) the last day for filing a return for that year (the 3-year period or the section 6229(a) assessment period). Section 6229(b)(1)(A) and (B), however, provides that the 3-year period may be extended. The 3-year period may be extended with respect to any partner by an agreement entered into by respondent and such partner, and may be extended with respect to all partners by an agreement entered into by respondent and (1) the tax matters partner or (2) any other person authorized by the partnership in writing to enter into such an agreement. See sec. 6229(b)(1)(A) and (B), respectively. The agreement must be executed prior to the expiration of the 3-year period, and any subsequent agreement must be executed before the expiration of the period previously agreed upon. Section 6229(d) suspends the running of the section 6229(a) assessment period upon the mailing of a notice of final partnership administrative adjustment (FPAA) to the tax matters partner (TMP) of the partnership. The running of the section 6229(a) assessment period is suspended for the period in which an action may be brought challenging the FPAA. If such an action is brought during that period, the suspension continues until the decision of the Court therein becomes final and for 1 year thereafter. See sec. 6229(d).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