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necessity, refer to section 6501. The only change made by
section 6229(a) is the proviso that whatever the applicable
“period for assessing any tax”, it shall not expire before the
minimum period.18 Indeed, in other instances where Congress has
used the "shall not expire before" language of section 6229, it
has done so without displacing one period of limitations by
another. See, e.g., sec. 6501(c)(7).19 We are convinced that if
Congress had intended to create a completely separate statute of
limitations for assessments attributable to partnership and
affected items, the drafters of section 6229 would have tracked
the language of section 6501(a) and simply provided that “any tax
attributable to partnership items or affected items shall be
18A similar analysis disposes of petitioner's identical
argument with regard to various regulations which reference the
sec. 6229(a) period as "the period of limitations." See sec.
301.6231(a)(1)-1T(b)(2), Temporary Proced. & Admin. Regs., 52
Fed. Reg. 6790 (Mar. 5, 1987), and sec. 301.6231(a)(6)-1, Proced.
& Admin. Regs.
19Sec. 6501(c)(7) provides:
SEC. 6501(c). Exceptions.--
* * * * * * *
(7) Special rule for certain amended returns.--
Where, within the 60-day period ending on the day on
which the time prescribed in this section for the
assessment of any tax imposed by subtitle A for any
taxable year would otherwise expire, the Secretary
receives a written document signed by the taxpayer
showing that the taxpayer owes an additional amount of
such tax for such taxable year, the period for the
assessment of such additional amount shall not expire
before the day 60 days after the day on which the
Secretary receives such document. [Emphasis added.]
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