IRS not limited to three years for FPAA.The Fifth Circuit held that IRC (Internet Relay Chat) Computer conferencing on the Internet. There are hundreds of IRC channels on numerous subjects that are hosted on IRC servers around the world. After joining a channel, your messages are broadcast to everyone listening to that channel. [section] 6229(a) sets no deadline by which the IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. must issue an FPAA FPAA Field-Programmable Analog Array FPAA Florida Prosecuting Attorneys Association FPAA Fairmount Park Art Association (Philadelphia, PA) FPAA Fresh Produce Association of the Americas FPAA Fire Protection Association of Australia (final partnership administrative adjustment). Its interpretation of the relationship between the limitations period in sections 6501(a) and 6229(a) mirrors that of the Tax Court, the D.C. Circuit and the Federal Circuit (see Rhone-Poulenc Surfactants & Specialties LP v. Commissioner, 114 TC 533; Andantech LLC (Logical Link Control) See "LANs" under data link protocol. LLC - Logical Link Control v. Commissioner, 331 E3d 972 (D.C. Cir. 2003); and AD Global Fund LLC ex rel. N. Hills Holding Inc. v. U.S., 481 E3d 1351 (Fed. Cir. 2007)). Curr-Spec Partners filed its 1999 Form 1065 on Oct. 11, 2000. More than four years later, on Oct. 13, 2004, the IRS issued an FPAA claiming the partnership was a sham, disallowing all income, deductions, gains and losses; treating partnership transactions as individual partner transactions; and assigning no basis for partnership interests. Curr-Spec argued section 6229(a) sets an independent three-year statute of limitations A type of federal or state law that restricts the time within which legal proceedings may be brought. Statutes of limitations, which date back to early Roman Law, are a fundamental part of European and U.S. law. for assessing tax attributable to partnership items. The IRS argued that at least three partners claimed NOL carryforwards of 1999 partnership items on their individual 2000 and 2001 returns, and thus the statute of limitations for individual returns under section 6501(a) remained open. The court noted section 6229(a) states the statute of limitations period "shall not expire before" three years from the date the partnership return was filed or, if later, when it was due. The Fifth Circuit said the phrase "shall not expire before" is unambiguous; that is, it can extend but never shorten the section 6501(a) period for assessing individual tax liabilities attributable to partnership items. After the FPAA becomes final, the IRS may assess tax on the individual partners whose tax returns remain open under section 6501(a). * Curr-Spec Partners LP v. Commissioner, docket no. 08-60815 (5th Cir., Aug. 11, 2009) By Melanie J. Earles, CPA (Computer Press Association, Landing, NJ) An earlier membership organization founded in 1983 that promoted excellence in computer journalism. Its annual awards honored outstanding examples in print, broadcast and electronic media. The CPA disbanded in 2000. , DBA, professor of accounting, Tennessee Technological University Tennessee Technological University, popularly known as Tennessee Tech, is an accredited public university located in Cookeville, Tennessee, a small city approximately seventy miles (110 km) east of Nashville. , Cookeville, Tenn. |
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