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who signed the June 17 TFV Form 872-P for 1985 was never a
partner of TFV. Nevertheless, respondent argues that the
September 29 TFV Form 872-P for 1985 was effective to extend the
3-year period for all of the partners of the partnership since
Mr. Wright was authorized by the partnership in writing to enter
into an agreement with respondent to so extend the 3-year period.
See sec. 6229(b)(1)(B).
For the same reasons set forth supra in section V.B.3., we
find that the September 29 TFV Form 872-P for 1985 was effective
to extend the 3-year period for 1985. The TFV FPAA was timely
issued.
VIII. Conclusion
None of the partnerships has sustained the affirmative
defense of statute of limitations; the FPAA’s issued to AVA and
TFV for the 1984 and 1985 taxable years are valid. The FPAA’s
issued to AVF, DV-85, and HFA-II for the 1985 taxable year are
valid.
In the partnerships’ reply brief, they state that
respondent’s opening brief identifies William K. Shipley as
Acting Regional Counsel and Mr. Shipley was a witness in this
case. The partnerships claim: “Any direct involvement by
Mr. Shipley in a case in which he testified would be
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