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general partner designated by the partnership to handle tax
matters or, if no general partner is so designated, the general
partner with the largest profits interest in the partnership at
the close of the taxable year. See sec. 6231(a)(7); Transpac
Drilling Venture 1982-12 v. Commissioner, 147 F.3d at 223 n.1.
Where the partnership has not designated its tax matters partner
and the Commissioner determines that it is impracticable to
determine which general partner has the largest profits interest,
the tax matters partner is that general or limited partner
selected by the Commissioner. See sec. 6231(a)(7); sec.
301.6231(a)(7)-1T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.
6791 (Mar. 5, 1987); see also Transpac Drilling Venture 1982-12
v. Commissioner, supra at 223 n.1.
Petitioner argues that respondent may not assess Federal
income tax as to either subject year because the 3-year periods
of limitation under section 6229(a) have expired as to those
years. Generally, the Commissioner must assess Federal income
tax as to a partnership item (or affected item) within 3 years
after the later of (1) the date on which the partnership files
its partnership return for the taxable year of assessment or (2)
the last date for filing that return (without extension). See
Madison Recycling Associates v. Commissioner, 295 F.3d. 280, 286
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