Kligfeld Holdings, Kligfeld Corporation, Tax Matters Partner - Page 22

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          partnership items.  Section 6229(a)--the key section in this                
          case--does refer to the partnership’s taxable year, but only in             
          reference to assessment of tax and not to adjustment of partner-            
          ship items.  Congress knows how to limit the Commissioner’s time            
          to adjust partnership items and not just his time to assess tax.            
          Look at section 6248(a), governing partnerships much larger than            
          Kligfeld’s.  It says:                                                       
                    SEC. 6248(a) General Rule.--Except as otherwise                   
               provided in this section, no adjustment under this                     
               subpart to any partnership item for any partnership                    
               taxable year may be made after the date which is 3                     
               years after the later of * * * [the filing date or due                 
               date] for such year * * *.                                             
          Unlike section 6248(a), section 6229(a) does not set a maximum              
          time limit to make adjustments.  Since section 6229(a) modifies             
          section 6501, and section 6501 sets a three-year general                    
          limitation period for assessments, we read the difference in                
          language between the two TEFRA provisions to indicate that                  
          Congress anticipated that the taxable year in which an assessment           
          is made would not always be the same as the taxable year in which           
          the adjustments are made.                                                   
               Kligfeld’s final textual argument points us toward three               
          additional TEFRA provisions that, he claims, imply that TEFRA               
          itself requires a matching of partnership and partner taxable               
               •    Section 6231(a)(7)(B)--general partner with                       
                    the largest interest “at the close of the                         

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