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renders a statutory provision superfluous should be avoided,
since it would offend ‘the well-settled rule of statutory
construction that all parts of a statute, if at all possible, are
to be given effect.’” Rhone-Poulenc Surfactants & Specialties,
L.P. v. Commissioner, supra at 547 (quoting Weinberger v. Hynson,
Westcott & Dunning, Inc., 412 U.S. 609, 633 (1973)).
In Rhone-Poulenc Surfactants & Specialties, L.P. v.
Commissioner, supra at 549-550, we emphasized the importance of
ensuring that extension agreements under section 6229(b)(3) be
precise:
Contract principles are pivotal in determining the
existence and scope of that agreement because section
6501(c)(4) requires a written agreement. Section
6229(b)(3) imposes a default rule for purposes of
determining whether an agreement encompasses
assessments that are attributable to partnership items.
* * * [Citations omitted.]
If we were to adopt respondent’s interpretation, such a course of
action would not only make the application of section 6229(b)(3)
of questionable significance, but also would leave doubt as to
whether the parties had a meeting of the minds, which the
application of section 6229(b)(3) avoids.
In interpreting section 6229(b)(3), we are cognizant of the
principle that limitations statutes barring the collection of
taxes otherwise due and unpaid are strictly construed in favor of
the Commissioner. Colestock v. Commissioner, 102 T.C. 380, 387
(1994) (citing Badaracco v. Commissioner, 464 U.S. 386, 391-392
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