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a notice of final partnership administrative adjustment. Since
respondent did not make any change in the gross income of the
partnership, the special rule of section 6229(c)(2) (substituting
6 years for 3 years in section 6229(a) on account of a
substantial omission of income from the partnership return) is of
no application. Nevertheless, if respondent’s adjustments are
sustained, it appears that petitioner has made a substantial
omission of income from its corporate return, with the
consequence that (absent adequate disclosure) the section 6501
period of limitations for the assessment of any tax with respect
to petitioner is 6 years rather than 3 years. See sec.
6501(e)(1)(A). As discussed above, section 6501 provides the
period of limitations within which "the amount of any tax imposed
by this title shall be assessed”. Sec. 6501(a). Section 6501
contains no exception for deficiencies attributable to
partnership items. Therefore, we shall not grant petitioner’s
motion to the extent it is based on the ground that section 6501
can have no possible application to this case.
3. FPAA Suspended the Section 6501 Period To
Assess Tax
a. Introduction
Petitioner next claims that, even if the 6-year period
specified in section 6501(e)(1)(A) is applicable, the 6-year
period has expired. Petitioner’s claim is based on the argument
that respondent’s issuance of the FPAA did not suspend the
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