Period of Limitations for Making Assessments

ID: CCA_2012081513524637 Number: 201239010
Release Date: 9/28/2012
Office: ---
UILC: 6229.00-00
From: ---
Sent: Wednesday, August 15, 2012 1:53:08 PM
To: ---
Cc: ---
Subject: RE: Questions for Counsel
The confusion stems from the fact that --- is looking at section 6229(a) as a separate statute from the partner's section 6501 statute. Its not. The "period under section 6229(a)" is the partner's section 6501 period as it applies to partnership items and which "shall not expire before" three years from the date the partnership return is filed. Rhone-Poulenc v. Commissioner, 114 T.C. 533, 552. There is no partnership statute of limitations and the partnership is not even a party to the TEFRA proceeding.