- 23 - (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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
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