- 18 - (1) The amount(s) of any Federal income tax with respect to any person on any partnership item(s) for the above partnership for the period(s) ended December 31, 1985 may be assessed at any time on or before April 30, 1991. If a notice of Final Partnership Administrative Adjustment is sent to the partnership, the time for assessing the tax for the period(s) stated in the notice of Final Partnership Administrative Adjustment will not end until 1 (one) year after the date on which the determination of partnership items becomes final. The AVA Form 872-P for 1985 shows AVA’s taxpayer identification number as 33-0044218. 7. AVA FPAA On April 10, 1991, respondent issued an FPAA to the partnership, addressed to “Tax Matters Partner” (the AVA FPAA), for its 1984 and 1985 taxable years. B. OPINION 1. 1984 Taxable Year a. Introduction Respondent issued the AVA FPAA to the partnership on April 10, 1991. Since such date is more than 3 years after the last day for filing the AVA 1984 Form 1065, see section 6072(a), we must determine whether that date is also more than 3 years after a valid AVA 1984 Form 1065 was received by respondent. See sec. 6229(a). If it is not, then the AVA FPAA was timely to suspend the running of the section 6229(a) assessment period, and AVA’s affirmative defense of statute of limitations fails for 1984. See also sec. 6229(c)(3). Respondent has responded toPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011