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(e) Substantial Omission of Items.--Except as
otherwise provided in subsection (c)--
(1) Income taxes.--In the case of any tax
imposed by subtitle A--
(A) General rule.--If the taxpayer
omits from gross income an amount properly
includible therein which is in excess of 25
percent of the amount of gross income stated
in the return, the tax may be assessed, or a
proceeding in court for the collection of
such tax may be begun without assessment, at
any time within 6 years after the return was
filed. For purposes of this subparagraph--
* * * * * * *
(ii) In determining the amount
omitted from gross income, there shall
not be taken into account any amount
which is omitted from gross income
stated in the return if such amount is
disclosed in the return, or in a
statement attached to the return, in a
manner adequate to apprise the Secretary
of the nature and amount of such item.
In pertinent part, section 6229 provides:
SEC. 6229(a). General Rule.--Except as otherwise
provided in this section, the period for assessing any
tax imposed by subtitle A with respect to any person
which is attributable to any partnership item (or
affected item) for a partnership taxable year shall not
expire before the date which is 3 years after the later
of--
(1) the date on which the partnership return
for such taxable year was filed, or
(2) the last day for filing such return for
such year (determined without regard to
extensions). [Emphasis added.]
Section 6501 unequivocally provides the period of
limitations within which "the amount of any tax imposed by this
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