- 53 - jurisdiction) and remanded to the Tax Court for further proceedings on the merits 249 F.3d 175 (3d Cir. 2001). See also CC & F W. Operations Ltd. Pship. v. Commissioner, T.C. Memo. 2000-286, affd. 273 F.3d 402 (1st Cir. 2001). In Rhone-Poulenc, we stated that section 6501(a) provides a general period of limitations for assessing and collecting any tax imposed by the Code. Section 6229(a) sets forth a minimum period for assessing any income tax with respect to any person that is attributable to any partnership item or affected item; this minimum period can be greater than, or less than, the period of limitations in section 6501. Id. at 540- 543. Section 6501 contains no exception for deficiencies attributable to partnership items. In drafting section 6229, Congress did not create a completely separate statute of limitations for assessments attributable to partnership items. Id. at 545. Section 6229 merely supplements section 6501. CC & F W. Operations Ltd. Pship. v. Commissioner, supra. Petitioners concede that under the holding of Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner, supra, the limitations period has not expired. They, however, request that we reconsider Rhone-Poulenc. We decline to do so. We hold, therefore, that the period of limitations for issuing the FPAAs for both 1993 short periods had not expired at the time the FPAAs were issued. Second, we rely upon Wind Energy Tech. Associates III v.Page: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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