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(1984)). Nevertheless, the period referenced in the statute is
the period described in section 6229(a), as we further described
in Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner,
114 T.C. 533 (2000).
III. Conclusion
Respondent’s notice of deficiency adequately references
affected items over which this Court has jurisdiction.
Nevertheless, on the basis of the statute and our precedent, we
conclude that to extend the period of limitations for affected
items the Forms 872 must specifically reference “partnership
items” as required by section 6229(b)(3). Respondent’s failure
to include any reference to tax attributable to partnership items
in the Forms 872 executed with petitioner results in the
expiration of the period of limitations for any affected items
adjustments respondent might raise in this case.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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