- 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 to
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011