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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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