- 24 -
should be avoided, since it would offend “the well-settled rule
of statutory construction that all parts of a statute, if at all
possible, are to be given effect.” Weinberger v. Hynson,
Westcott & Dunning, Inc., 412 U.S. 609, 633 (1973); Woods v.
Commissioner, 91 T.C. 88, 98 (1988). We shall not, however, do
violence to the clear language of the statute in furtherance of a
rule of statutory construction. In any event, we are not
convinced that respondent’s position renders section
6229(c)(1)(A) superfluous. We have set forth sections
6229(c)(1)and 6501(c)(1) in the margin.24 Both sections deal
24Sec. 6229(c)(1) provides:
SEC. 6229(c). Special Rule in Case of Fraud, Etc.--
(1) False return.--If any partner has, with the
intent to evade tax, signed or participated directly or
indirectly in the preparation of a partnership return
which includes a false or fraudulent item–
(A) in the case of partners so signing or
participating in the preparation of the return,
any tax imposed by subtitle A which is
attributable to any partnership item (or affected
item) for the partnership taxable year to which
the return relates may be assessed at any time,
and
(B) in the case of all other partners,
subsection (a) shall be applied with respect to
such return by substituting “6 years” for
“3 years.”
Sec. 6501(c)(1) provides:
SEC. 6501(c). Exceptions.--
(continued...)
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