Alan H. Ginsburg and Estate of Harriet F. Ginsburg, Deceased, Alan H. Ginsburg, Personal Representative - Page 23

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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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