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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
Pronouncements
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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