- 44 -
as the grant made by the agreement in Cambridge Research & Dev.
Group v. Commissioner, supra. Section 26.6 of the agreement (the
same as sec. 26.6 of the AVA limited partnership agreement; see
supra sec. III.A.2), providing that the general partners shall
designate one of them TMP, confirms that drafters of the
agreement contemplated that a general partner would have the
authority to extend the 3-year period for all of the partners of
the partnership. See sec. 6229(b)(1)(B). The fact that the
general partners were not successful in designating one of
themselves TMP, a position which carries responsibilities in
addition to entering into an agreement with the Secretary to
extend the 3-year period, does not convince us that the drafters
of the agreement intended such extension to be accomplished only
by a general partner successfully designated TMP. We believe
that, when read in the light of the California Revised Limited
Partnership Act, the DV-85 limited partnership provided the
authority for a general partner of the partnership to enter into
an agreement to extend the 3-year period with respect to all the
partners of the partnership, and we so find. The DV-85 Form
872-P for 1985, executed by Mr. Schreiber and delivered to
respondent, is evidence that Mr. Schreiber had authority to
execute that document. See section 11.2.b of the DV-85 limited
partnership agreement, which is identical to the same section of
the AVA limited partnership agreement, set forth supra in section
III.A.2. The partnership has failed to prove that
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