Kligfeld Holdings, Kligfeld Corporation, Tax Matters Partner - Page 14

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          partnership return, it must notify the individual partners of the           
          adjustment by issuing an FPAA.  Sec. 6223(a).  The TMP has ninety           
          days after the Commissioner mails an FPAA to petition for its               
               The specific TEFRA provision at issue in this case is                  
          section 6229, which states:                                                 
               SEC. 6229.  PERIOD OF LIMITATIONS FOR MAKING ASSESSMENTS.              
                    (a) General Rule.--Except as otherwise provided in                
               this section, the period for assessing any tax imposed                 
               by subtitle A with respect to any person which is                      
               attributable to any partnership item (or affected item)                
               for a partnership taxable year shall not expire before                 
               the date which is 3 years after* * *                                   
                         (1) the date on which the partnership return                 
                    for such taxable year was filed * * *.                            
                     *      *      *      *      *      *      *                      
                    (d) Suspension When Secretary Makes Administrative                
               Adjustment.--If notice of a final partnership                          
               administrative adjustment with respect to any taxable                  
               year is mailed to the tax matters partner, the running                 
               of the period specified in subsection (a) * * * shall                  
               be suspended--                                                         
                         (1) for the period during which an                           
                    action may be brought under section 6226                          
                    (and, if a petition is filed under section                        
                    6226 with respect to such administrative                          
                    adjustment, until the decision of the court                       
                    becomes final), and                                               
                         (2) for 1 year thereafter.                                   

               17 The TMP can seek readjustment in either the Tax Court,              
          the Court of Federal Claims, or a U.S. District Court.  Sec.                

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