§1284

Moreover, it is unclear whether the "return" specified in section 6501(c)(1) included partnership returns, though we need not address that question here.

1284, 111 Stat. at 1038, which in part amended section 6501(a). One ofits specifically intended purposes was to clarify this issue with respect to S corporations. See Robinson v. Commissioner, 117 T.C. at 317 (and legislative history cited thereat). The legislative history explains that the new provision is intended to clarify that the return

.C. 490 (1992). The Manning opinion did not provide any rationale in addition to that contained in the cited cases. Although prospective and not in effect for the tax year under consideration (1992), the Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1284, 111 Stat. 1038, added the following language to section 6501(a): For purposes of this chapter, the term “return” means the return required to be filed by the taxpayer (and does not include a return of any person from whom the taxpayer has r