- 8 - In drafting section 6229, Congress did not create a completely separate statute of limitations for assessments attributable to partnership items. See AD Global Fund, LLC v. United States, 481 F.2d 1351 (Fed. Cir. 2007); Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner, supra at 545. Instead, section 6229 merely supplements section 6501. In Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner, supra at 539, the Court analyzed sections 6229 and 6501 as applicable to an FPAA. The Court stated in pertinent part: The Internal Revenue Code prescribes no period during which TEFRA partnership-level proceedings, which begin with the mailing of the notice of final partnership administrative adjustment, must be commenced. However, if partnership-level proceedings are commenced after the time for assessing tax against the partners has expired, the proceedings will be of no avail because the expiration of the period for assessing tax against the partners, if properly raised, will bar any assessments attributable to partnership items. [Id. at 534-535.] * * * * * * * * * * Any income tax attributable to partnership items is assessed at the partner level. Thus, any statute of limitations provisions that limit the time period within which assessment can be made are restrictions on the assessment of a partner’s tax. [Id. at 539.] See AD Global Fund, LLC v. United States, 481 F.2d 1351 (Fed. Cir. 2007); G-5 Inv. Pship. v. Commissioner, 128 T.C. ___ (May 30, 2007).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007