Limitations on Assessment and Collection (Barred v. Not Barred)

ID: CCA_2012062012002937 Number: 201235020
Release Date: 8/31/2012
Office: ---
UILC: 6501.00-00
From: ---
Sent: Wednesday, June 20, 2012 12:00:46 PM
To: ---
Cc: ---
Subject: RE: TEFRA Question
The statute is open indefinitely for the non-filing indirect partners. I.R.C. 6501(c)(3). Three circuit courts of appeal and an en banc opinion of the Tax Court have held that section 6229 does not shorten a partner's section 6501 statute with respect to partnership items. Section 6229 merely provides a minimum period during which no partner's section 6501 statute can expire with respect to partnership items.