United States Federal Circuit

Internal Revenue Code section 6229(a) does not provide a separate statute of limitations for assessing taxes on partnership items, but simply creates a minimum period that may extend the regular statute of limitations for partnership items.

Appellate Information

• Decided 03/02/2007
• Published 03/02/2007

Judges

• WHYTE, District Judge., Before MAYER, PROST, Circuit Judges, and WHYTE, District Judge.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• David D. Aughtry, Chamberlain, Hrdlicka, White, Williams & Martin, of Atlanta, GA, argued for plaintiff-appellant.   With him on the brief was Juan F. Vasquez, Jr. Of counsel was Kevin D. Jewell, of Houston, TX., M. Todd Welty, Meadows, Owens, Collier, Reed, Cousins & Blau, L.L.P., for amici curiae, J&J Fernandez Ventures, L.P., et al.


• For Appellees:
  
• Eileen J. O'Connor, Assistant Attorney General, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee.   With her on the brief were Richard T. Morrison, Deputy Assistant Attorney General, and Gilbert S. Rothenberg, Robert W. Metzler, and Michael J. Haungs, Attorneys.