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describes an “add on” period that, in some circumstances, extends
the period prescribed by section 6501 but would never subtract
from that period. Respondent concedes that, if we agree with
petitioner, the motion should be granted.
2. Petitioner’s Claims
Petitioner claims (and respondent agrees) that (1) more than
3 years elapsed between both the due date and filing of the
partnership return and the issuance of the FPAA, and (2) the
partnership did not omit any amount from gross income. On that
basis, petitioner claims that any assessment of tax with respect
to respondent’s adjustments is barred by the 3-year period of
limitations found in section 6229(a). In response to
respondent’s argument that section 6229(a) merely extends the
section 6501 period in some instances and is inapplicable in this
case, petitioner answers: (1) Section 6501 is inapplicable to
the assessment of any tax attributable to any partnership item,11
11 The parties are in agreement that this case involves one
or more partnership items. Respondent claims that, if his
determination of partnership items is sustained, nonpartnership
items of one or more partners will be affected (affected items),
resulting in computational adjustments to the tax liabilities of
those partners. See sec. 6231(a)(4),(5), and (6); sec.
301.6231(a)(6)-1T, Temporary Proced. & Admin. Regs., 51 Fed. Reg.
13231 (Apr. 18, 1986). If the determination of any affected item
requires a partner-level determination, then the deficiency
procedures contained in secs. 6211 through 6216 will apply to the
determination of such affected item. See sec. 6230(a)(2). If
the determination of any affected item does not require a
partner-level determination, then the aforementioned deficiency
procedures will not apply to the determination of such affected
(continued...)
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