- 11 - partnership proceeding becomes final, respondent may assess a tax liability for a year open under the period of limitations, even though the underlying partnership item adjustments are attributable to transactions that were completed in a year for which assessments of the partners’ tax is barred because of the expiration of the period of limitations. In this case, although the periods prescribed by sections 6229(a) and 6501(a) have run for 2000 and 2001, the FPAA determined adjustments to partnership items (capital losses) that may have income tax consequences to the partners at the partner level in 2002-04, years open under the period of limitations. If the adjustments to partnership items in the FPAA are sustained, respondent may assess a computational adjustment or determine a deficiency against the partners for those open years. However, respondent concedes that, because the tax years 2000 and 2001 are closed, respondent is barred from assessing any deficiencies, penalties or additions to tax with respect to the partners’ 2000 and 2001 tax years. This Court finds that respondent’s issuance of the FPAA on April 12, 2006, for G-5’s 2000 tax year was not barred by any period of limitations13 and that the period of limitations for assessing taxes attributable to partnership items for 13 See Kligfeld Holdings v. Commissioner, 128 T.C. ___ (2007).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007