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the “period for assessing any tax imposed by subtitle A” rather
than just the minimum period language.32
Interpreting “the period specified in subsection (a)” in
section 6229(d) as referring only to the minimum period for
making assessments would produce additional anomalous results.
For example, suppose that during the examination of a
partnership, and within 3 years of the filing of the partnership
return, the Commissioner and most of the partners agree to extend
the period of limitations as to partnership items. The only
partners who do not extend the period of limitations are those
who failed to file individual returns and could not be located.
More than 3 years after the filing of the partnership return and
due date, but prior to the end of the period as extended, an FPAA
is issued. Under any possible interpretation of section 6229(d),
the FPAA suspends the period of limitations for assessments
attributable to any partnership item (or affected item) for the
partners who signed extensions. Under section 6501(c)(3), the
tax for those partners who did not file individual returns can be
assessed at any time. However, if the partners who failed to
file timely individual returns, file their individual returns
after a partnership-level proceeding is commenced, the normal 3-
32We recognize that sec. 6229(d) uses the word “specified”
and sec. 6229(b) uses the word “described” when referring to
subsection (a). We discern no difference in meaning between the
two words in this context.
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