Rhone Poulenc Surfactants and Specialties, L.P. - Page 16




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          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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