Rodney J. and Noreen E. Blonien - Page 36




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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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