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Commissioner’s income tax determinations prior to assessment and
collection. The general statutory scheme provides that no
assessment of a deficiency can be made prior to notice and an
opportunity to petition this Court. See sec. 6213. While issues
are pending before this Court, the period of limitations for
assessment is generally suspended. Section 6503 provides that
the mailing of a valid deficiency notice suspends the running of
the period of limitations with respect to the tax liability that
is the subject of such notice. In the event a petition is filed
with this Court, section 6503(a) also suspends the running of the
period of limitations until 60 days after the decision of this
Court becomes final. This protects the Government against the
running of the period of limitations during the time when it is
statutorily prohibited from assessing any deficiency.
The TEFRA partnership provisions, which provide for
partnership issues to be determined at the partnership level,
parallel the deficiency procedures to the extent that notice (the
FPAA) and the right to petition this Court must generally be
given prior to making any assessments attributable to partnership
items or affected items. See secs. 6225 and 6226. Section
6229(d) is the partnership-level counterpart to section 6503 in
that it provides for the suspension of the running of the period
of limitations during the period in which the Government is
prohibited from assessing tax attributable to a partnership item
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