Rhone Poulenc Surfactants and Specialties, L.P. - Page 37




                                        - 37 -                                        
          Taxation, par. 20.08[2][a] (6th ed. 1999), it is explained:  “A             
          standard extension of the limitations period under �6501(c)(4)              
          (Treasury Form 872) with respect to nonpartnership items does not           
          apply to partnership and affected items unless it specifically so           
          provides.”  See also Cohen & Millman, “The Statute of Limitations           
          for Partners”, 5 J. Psp. Taxn. 256, 257 (1988).  However, if the            
          language in section 6229(b)(3) requiring an express provision for           
          partnership items is interpreted to apply only when extending the           
          minimum period of limitations in subsection (a), the legislative            
          purpose would be thwarted.  Such a narrow interpretation of “the            
          period described in subsection (a)” would mean that the                     
          specificity required in an extension agreement referred to in               
          section 6229(b)(3) was required only to extend the minimum                  
          period.  There would be no such requirement to refer explicitly             
          to partnership-related assessments when extending the regular               
          periods of limitations provided in section 6501.  But this is               
          clearly not what Congress intended by section 6229(b).  The only            
          way to achieve the legislative objective is to interpret the                
          reference in section 6229(b)(3) consistently with the way we                
          interpreted section 6229(d).  Thus, the reference in section                
          6229(b)(3) to “the period described in subsection (a)” refers to            











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