Agri-Cal Venture Associates, Frederick H. Behrens, Tax Matters Partner, et al. - Page 7




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          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).                                              




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