-18-
corresponding dates. Accordingly, assessments for the subject
years are barred by the 3-year rule of section 6229(a), given
that Leatherstocking filed the subject returns on May 29, 1984,
and April 22, 1985, respectively, and respondent issued the FPAAs
more than 3 years later, on September 16, 1997.
Respondent argues that the 3-year rule of section 6229(a)
does not apply because the periods of limitation for assessment
for both years were extended to December 31, 1997, or in other
words, to a date after the FPAAs were issued. The 3-year period
of limitation set forth in section 6229(a) is extended with
respect to all partners if, before that period expires (including
any periods covered by a prior extension), the Commissioner
receives the consent of: (1) All partners or (2) the
partnership’s TMP or any other person authorized by the
partnership in writing to enter into such an agreement. See sec.
6229(b)(1); Transpac Drilling Venture 1982-12 v. Commissioner,
supra at 224. Petitioner acknowledges that Steele, designated
Leatherstocking’s TMP, executed Forms 872-P with respect to
Leatherstocking. Respondent also produced the facially valid
forms to rebut petitioner’s periods of limitation defense. See
Lefebvre v. Commissioner, T.C. Memo. 1984-202 (consent to extend
a period of limitation is valid on its face if it is signed
before the end of the limitation period and includes the name of
the taxpayer, the signature of the taxpayer or a person
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