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actually was obtained pursuant to that misrepresentation.
Petitioner claims that, as a result of respondent’s concealment
of his criminal investigation, respondent was able to obtain
“putative extensions” of the statute of limitations. We have
found that the 1986 partnership return (a calendar-year return)
was timely made and that the FPAA was dated (and, we assume,
mailed) on March 14, 1990. On the face of it, respondent had no
need of any extension of the period of limitations, see section
6229(a), (d), and, in any event, petitioner has failed to prove
that any agreement to extend the section 6229(a) period was
entered into by any partner or any other person with authority to
bind the partnership. See sec. 6229(b).7
7 Petitioner may have in mind agreements to extend the sec.
6229(a) period of limitations entered into by partners of other
partnerships sponsored by AMCOR. Throughout the course of
petitioner’s memoranda, petitioner fails clearly to relate his
complaints to the partnership or distinguish between harms
alleged to have been suffered by the partnership and harms
suffered by AMCOR, its principals, or the remaining AMCOR
sponsored partnerships. Respondent and the tax matters partners
in certain related cases have stipulated that they will be bound
in those cases by our order on the motion. During the course of
the hearing, we cautioned petitioner that the hearing concerned
only the motion, which pertained only to the partnership.
Respondent opposed the motion, and participated in the hearing,
on the basis that the motion concerned only the partnership. As
we said supra sec. III., we shall examine how respondent
conducted himself with respect to the partnership and not how he
conducted himself with respect to any other person, except to the
extent such person was acting for the partnership.
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