Rhone Poulenc Surfactants and Specialties, L.P. - Page 11




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          confusing”.  Foxman v. Commissioner, 41 T.C. 535, 551 n.9 (1964),           
          affd. 352 F.2d 466 (3d Cir. 1965).                                          
               Subtitle F of the Code is concerned with procedure and                 
          administration.  Both section 6229 and section 6501 are contained           
          in subtitle F.  Section 6229 is one of a group of provisions                
          concerning the tax treatment of partnership items that was added            
          to the Code by TEFRA.  For income tax purposes, partnerships are            
          not taxable entities (see section 701, which reflects the view              
          that a partnership is no more than an aggregation of its                    
          members).  Any income tax attributable to partnership items is              
          assessed at the partner level.  Thus, any statute of limitations            
          provisions that limit the time period within which assessment can           
          be made are restrictions on the assessment of a partner’s tax.              
               Before TEFRA, adjustments with respect to partnership items            
          were made to each partner’s income tax return at the time (and              
          if) that return was examined.  See H. Conf. Rept. 97-760, at 599            
          (1982), 1982-2 C.B. 600, 662.  An administrative settlement or              
          judicial determination of a disagreement between a partner (or              
          partners) and the Commissioner bound only the parties thereto and           
          did not bind other partners or bind the Commissioner with respect           
          to other partners.  See id.  The tax writing committees explained           
          the TEFRA partnership provisions as follows:  “[T]he tax                    
          treatment of items of partnership income, loss, deductions, and             
          credits will be determined at the partnership level in a unified            






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