- 54 - Tex. Rev. Civ. Stat. Ann. art. 6132a (West 1970). TFV has failed to prove that AMCOR was admitted as a co-general partner of the partnership in accordance with TULPA section 10(5) on or before February 5, 1985. We reject TFV’s other arguments for the reasons set forth supra in section III.B.1.e.(1) and (2).8 We find that the TFV 1984 Form 1065 was not signed by any partner who had authority to sign it, and, consequently, it was not a valid partnership return. The TFV FPAA was issued before expiration of the section 6229(a) assessment period and was effective to suspend the running of that period. See supra sec. III.B.1.f. 2. 1985 Taxable Year The issue here is the same as it is with respect to DV-85 for 1985. See supra sec. V.B. The partnership timely filed the TFV 1985 Form 1065, and, unless the 3-year period was extended, the TFV FPAA, issued on April 10, 1991, was issued after the expiration of the 3-year period. Respondent relies on the September 29 TFV Form 872-P for 1985 to show such extension. There are technical defects in the June 16 and September 29 letters, and respondent concedes that neither of them complies with the requirements of section 301.6231(a)(7)-1T(e), Temporary Proced. & Admin. Regs., 42 Fed. Reg. 6791 (Mar. 5, 1987), for designating a TMP. Also, respondent concedes that Mr. Schreiber, 8 TFV has not produced any agreement by which AMCOR was engaged as managing partner of the partnership.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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