- 23 -
permitted to participate as a party in the partnership proceeding
“solely for the purpose of asserting that the period of
limitations for assessing any tax attributable to partnership
items has expired with respect to such person”. See last
sentence of sec. 6226(d)(1)(B) added to the Code by the Taxpayer
Relief Act of 1997, Pub. L. 105-34, sec. 1239(b), 111 Stat. 1027-
1028, effective for years ending after August 5, 1997.23
f. Internal Superfluities
Finally, petitioner argues that respondent’s position
creates internal superfluities in section 6229. Petitioner
explains that section 6229(c)(1)(A) provides an unlimited section
6229(a) assessment period for deficiencies attributable to
partnership items and affected items of a partner who, acting
with intent to evade taxes, signs or participates in the
preparation of a false or fraudulent partnership return. Section
6229(c)(1)(A), petitioner argues, is superfluous if the
controlling statute of limitations on assessments of deficiencies
attributable to partnership items and affected items is contained
in section 6501, because section 6501(c)(1) contains an identical
unlimited assessment period.
Again, petitioner's arguments are not persuasive. An
interpretation that renders a statutory provision superfluous
23See supra note 4, containing the complete addition to sec.
6226(d)(1)(B).
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