- 31 - Issue 2. Whether the Period of Limitations on Assessment Had Expired When the FPAAs Were Issued The period for making assessments of tax attributable to a partnership item or affected item is set forth in section 6229. Section 6229 provides in pertinent part: 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 the later of-- (1) the date on which the partnership return for such taxable year was filed, or (2) the last day for filing such return for such year (determined without regard to extensions). (b) Extension by Agreement.-- (1) In general.--The period described in subsection (a) (including an extension period under this subsection) may be extended-- * * * * * * * (B) with respect to all partners, by an agreement entered into by the Secretary and the tax matters partner (or any other person authorized by the partnership in writing to enter into such an agreement), before the expiration of such period. * * * * * * *Page: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007