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filing its return without extensions is April 15, the period of
assessment does not expire until 3 years after April 15.
The only exceptions to this rule are provided by statute for
the filing of a false partnership return, a substantial omission
of partnership income, no partnership return, or a partnership
return prepared by the Secretary under section 6020(b)(2). See
sec. 6229(c)(1)-(4). In addition a partner may extend the
section 6229(a) statute of limitations for himself, or the tax
matters partner may, with the agreement of the Secretary, extend
the statutory limitations period for all partners. See sec.
6229(b)(1). Therefore, the section 6229(a) period of limitations
is not extended by a partner's later expiring section 6501
limitation period.
In holding that section 6229 provides nothing more than a
"minimum period" of limitations as an alternative to the section
6501 limitations period, the majority abandons our own precedent
that section 6229(a) establishes the limitations period for
assessment of partnership items. See Wind Tech. Associates, III
v. Commissioner, 94 T.C. 787, 788 (1990) ("Section 6229(a)
provides generally for a 3-year period of limitations for the
assessment of tax attributable to partnership items. * * * The
running of the limitations period is suspended when an FPAA for
the taxable year is mailed to the tax matters partner." (citation
omitted.)); Barbados #7 Ltd. v. Commissioner, 92 T.C. 804, 808
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