Case: Deficiency Assessments Arising from Partnership Adjustments Timely, Period Extended Because Petitioners Were “Unidentified Partners” (T.C. Memo) (IRC §6229)

Notices of deficiency (NODs) for tax years 1996 and 2001, issued to Petitioners on March 12, 2021, attributable to partnership adjustments finalized on May 17, 2018, following a decision of the Court of Appeals for the D.C. Circuit, were valid because the period of limitations for tax assessments against Petitioners remained open under former I.R.C. §6229(e), the U.S. Tax Court held in a memorandum opinion, granting the government’s motion for summary judgment. The court rejected Petitioners’ argument that the NODs were invalid because the period of limitations expired under former §6229(d) in May 2019, one year after the partnership adjustments ...