Alan H. Ginsburg and Estate of Harriet F. Ginsburg, Deceased, Alan H. Ginsburg, Personal Representative - Page 19

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          which is “the period for assessing any tax imposed by subtitle A            
          with respect to any person which is attributable to any                     
          partnership item (or affected item) for a partnership taxable               
          year”.  Sec. 6229(a).  Accordingly, respondent’s position is                
          inconsistent with the statute because respondent confuses what is           
          required to be in the agreement extending the period of                     
          limitations with the period extended.                                       
               D.   Respondent’s Position Is Inconsistent With Prior                  
                    Caselaw, Secondary Authority, and Respondent’s Own                
               Our conclusion that section 6229(b)(3) applies to affected             
          items is further solidified by our Court-reviewed Opinion in                
          Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner,              
          114 T.C. 533 (2000).  We provided a detailed explanation of the             
          scope of section 6229(b)(3) and its coordination with section               
          6501(c)(4).  We stated that those sections were “intended to                
          allow taxpayers and the Commissioner to extend the period of                
          limitations for assessments of tax attributable to partnership              
          items only where the extension agreement expressly provides that            
          it applies to tax attributable to partnership items.”  Id. at               
          555.  We further quoted a treatise regarding the scope of the               
          rule in section 6229(b)(3):  “‘A standard extension of the                  
          limitations period under section 6501(c)(4) (Treasury Form 872)             
          with respect to nonpartnership items does not apply to                      

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