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title shall be assessed”. Sec. 6501(a) (emphasis added).
Generally, the period of limitations so provided is 3 years from
the date the taxpayer’s return was filed but varies in the case
of certain enumerated exceptions. See, e.g., sec. 6501(c), (d),
(e), (f), (h). The pertinent language of section 6229 is:
"[T]he 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" the
filing or due date of the partnership return. (Emphasis added.)
Section 6229 provides a minimum period of time for the assessment
of any tax attributable to partnership items (or affected items)
notwithstanding the period provided for in section 6501, which is
ordinarily the maximum period for the assessment of any tax. The
section 6229 minimum period may expire before or after the
section 6501 maximum period.13 Indeed, section 6501(n)(2) cross-
references section 6229 by providing: "For extension of period
13For example, the 3-year minimum period described in sec.
6229(a) will expire on April 15 of year four in the case of a
partnership return timely made (without extension) for year one
(a calendar year), while the 3-year maximum period described in
sec. 6501 will expire on August 15 of year four in the case of an
individual partner’s return made (with automatic 4-month
extension) for year one. If a partner is a corporation, which
timely makes its return (without extension) for year one on March
15 of year two, the 3-year maximum period described in sec. 6501
will expire 1 month earlier (on March 15 of year four) than the
3-year minimum period described in sec. 6229(a).
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