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assessing any tax imposed by subtitle A”30 and not just the
minimum period included in subsection (a) is also supported by
the same interpretation that is required to achieve the
congressional purpose in section 6229(b)(3), which provides:
SEC. 6229(b). Extension by Agreement.--
* * * * * * *
(3) Coordination with section 6501(c)(4).--
Any agreement under section 6501(c)(4) shall apply
with respect to the period described in subsection
(a) only if the agreement expressly provides that
such agreement applies to tax attributable to
partnership items. [Emphasis added.31]
As previously explained, the above-quoted provision was
intended to allow taxpayers and the Commissioner to extend the
period of limitations for assessments of tax attributable to
partnership items only where the extension agreement expressly
provides that it applies to tax attributable to partnership
items. Thus, the conference committee report for TEFRA states:
“An agreement under section 6501(c)(4) (relating to agreements to
extend the period for assessment) will apply to partnership items
only if it expressly so provides.” H. Conf. Rept. 97-760, at 606
(1982), 1982-2 C.B. 600, 665. In 2 Willis et al., Partnership
30The tax referred to in sec. 6229(a) is restricted to tax
“attributable to any partnership item (or affected item)”. Sec.
6229(a).
31TRA sec. 1233(c), 111 Stat. 1023-1024, amended Code sec.
6229(b). Prior to the amendment, sec. 6229(b)(3) was sec.
6229(b)(2).
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