- 16 -
in the case of partnership items (as defined in section
6231(a)(3)), see section 6229." (Emphasis added.)14
The Court has often stated our understanding that section
6229 extends the section 6501 period with respect to tax
attributable to partnership items or affected items. See Estate
of Quick v. Commissioner, 110 T.C. 172, 181-182 (1998),
supplemented by Estate of Quick v. Commissioner, 110 T.C. 440
(1998) ("Section 6501(a) provides generally that respondent has 3
years from the date the return was filed in which to assess the
tax. Section 6501(o) provides a cross-reference to section 6229,
which extends such period in the case of adjustments pertaining
to partnership items or affected items.");15 Harris v.
Commissioner, 99 T.C. 121, 131 (1992), affd. 16 F.3d 75 (5th Cir.
1994) ("The section 6229 limitations period acts to extend the
limitations period otherwise available under section 6501 when
such period has otherwise expired."); Maxwell v. Commissioner, 87
T.C. 783, 791 n.6 (1986) ("See section 6229(a) which extends the
period of limitations for assessments of tax 'attributable to any
partnership item (or affected item).'"). However, we must
14We are aware that sec. 7806(a) provides that cross-
references are made only for convenience and have no legal
effect. However, it is still noteworthy that the cross-reference
speaks of an “extension” of the period of limitations.
15Sec. 6501(o) was changed to sec. 6501(n)(2) by the Deficit
Reduction Act of 1984, Pub. L. 98-369, sec. 163(b)(1), 98 Stat.
697.
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