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adjuncts to, and parts of, the 1st-tier partnerships’
information returns, which in turn are treated as adjuncts
to, and parts of, petitioner’s tax returns.
Craig A. Etter, Timothy J. Jessell, and Michael I. Sanders,
for petitioners.
Carol E. Schultze, for respondent.
OPINION
CHABOT, Judge: This matter is before us for determination
as to whether, in applying the 6-year period of limitations (sec.
6501(e)(1)(A))1, when a petitioner’s tax return reflects income
from a partnership (hereinafter sometimes referred to as the 1st-
tier partnership) that is itself a partner in another partnership
(hereinafter sometimes referred to as the 2d-tier partnership),
the statutory phrase “gross income stated in the return” (the
denominator in the 25-percent test) requires a tracing of the
flow of gross income from not only the 1st-tier partnership’s
information return but also from the 2d-tier partnership’s
information return in order to determine petitioners’ appropriate
1Unless otherwise indicated, all subtitle, chapter,
subchapter, and section references are to subtitles, chapters,
subchapters, and sections of the Internal Revenue Code of 1954 as
in effect for 1985; except that references to section 6501 are to
section 6501 of the Internal Revenue Code of 1986 as in effect
for notices of deficiency mailed in 1992.
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