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Unformatted text preview: CHAPTER 6 PARTNERSHIP AUDIT PROCEDURES DISCUSSION QUESTIONS 1. Answer: (A) Nellie. She may file as a “notice partner and not as TMP. A notice partner or any 5% group may file a petition within the 60-day period following the expiration of the 90-day period within which the TMP must file a readjustment petition. See Barbados #6, Ltd., 85 TC 900 (1985), CCH Dec. 42,522; Hoyt & Sons Ranch Props. v. Commissioner, T.C. Memo 1998-77. (B) Nellie, as a “partner must deposit only that amount equal to the deficiency in tax that would result if the adjustment is upheld. 2. Answer: (A) Connie may bring action with respect to her claim at any time within two years of the mailing of the notice, i.e., September 15, 2011. (B) Suit can be commenced after the expiration of six months from the date she filed the RAA. However, if the partnership had been given notice of the beginning of a partnership proceeding with respect to the preceding year before Connie filed suit, she would not be able to commence...
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This note was uploaded on 09/08/2011 for the course ECON 3301 taught by Professor Clavin during the Spring '10 term at Hartford.
- Spring '10