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returns of NPI will not prevent the 6-year period of limitations
of section 6501(e) from applying to the Bensons’ 1989, 1990,
1993, and 1994 tax years.
Neither section 6501(e)(1)(A)(ii) nor the caselaw
interpreting that section requires respondent to examine the
corporate returns of ERG in search of “clues” that disclose
income. The Bensons have not cited any authority to support
their contention that the returns of a taxable subchapter C
corporation serve as an adjunct to an individual taxpayer’s
return for purposes of section 6501(e)(1)(A)(ii). Instead, the
Bensons rely on Benderoff v. United States, 398 F.2d 132 (8th
Cir. 1968), and Roschuni v. Commissioner, 44 T.C. 80 (1965),
which involve the returns of subchapter S corporations. This
Court has explained that the returns of subchapter S corporations
and partnerships should be examined in conjunction with the
individual taxpayer’s return because these entities are
passthrough entities. See Harlan v. Commissioner, 116 T.C. at 54
(“when the taxpayers’ tax returns stated taxable income from
partnerships or S corporations, we declared that the information
returns of these pass-through entities would be treated as
adjuncts to, and part of, the taxpayers’ tax returns”); Roschuni
v. Commissioner, supra at 85-86. As a subchapter C corporation,
ERG is a taxable entity, it does not have the passthrough aspects
of an S corporation, and it files income tax returns, not
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