Rhone Poulenc Surfactants and Specialties, L.P. - Page 53

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          administrative adjustment made by respondent to partnership                 
          items, is antithetical to the unified nature of a partnership               
          proceeding.  I would interpret section 6229(d) consistently with            
          the entity theory of partnership reflected in Congress’                     
          establishment of the 3-year minimum period.  I would, therefore,            
          interpret the phrase “the period specified in subsection (a)” as            
          a reference to the 3-year minimum period.                                   
          III.  Conclusion                                                            
               I believe that the better reading of section 6229(d) is that           
          the period specified in subsection (a) is the 3-year minimum                
          period.  I reach the same result as the majority, however,                  
          because of my position in GAF Corp. & Subs. v. Commissioner,                
          supra.                                                                      
               WHALEN and BEGHE, JJ., agree with this concurring opinion.             

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