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examined. * * * The tax-writing committees explained
the TEFRA partnership provisions as follows: “[T]he
tax treatment of items of partnership income, loss,
deductions, and credits will be determined at the
partnership level in a unified partnership proceeding
rather than in separate proceedings with the partners.”
In Greenberg Bros. Pship. #4 v. Commissioner, 111 T.C. 198, 201
(1998), we explained that “The principal purpose behind TEFRA is
to provide consistency and reduce duplication in the treatment of
‘partnership items’ by requiring that they be determined in a
unified proceeding at the partnership level.”
In order to achieve the goal of having partnership items
(which ultimately affect each partner’s tax liability) determined
in a single proceeding at the partnership level, Congress enacted
section 6229, which extends the period of limitations applicable
to assessment of deficiencies against the individual partners
relating to the adjustment of partnership items:
SEC. 6229(a). General Rule.--Except as otherwise
provided in this section, the period for assessing any
tax * * * which is attributable to any partnership item
(or affected item) for a partnership taxable year shall
not expire before the date which is 3 years after the
later of–-
(1) the date on which the partnership return
for such taxable year was filed, or
(2) the last day for filing such return
for such year (determined without regard to
extensions.
The limitations period can be extended for a particular partner
by agreement with that partner, or for all partners by the tax
matters partner. Sec. 6229(b)(1). The period is suspended
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