§4226 — Repealed. Pub. L. 94–455, title XIX, § 1904(a)(4), Oct. 4, 1976, 90 Stat. 1811]

2 cases·2 cited

Statute Text — 26 U.S.C. §4226

[§ 4226. Repealed. Pub. L. 94–455, title XIX, § 1904(a)(4), Oct. 4, 1976, 90 Stat. 1811] Section, added June 29, 1956, ch. 462, title II, § 207(a), 70 Stat. 391; amended Sept. 21, 1959, Pub. L. 86–342, title II, § 201(c)(1)–(3), 73 Stat. 614; June 29, 1961, Pub. L. 87–61, title II, § 206(a), (b), 75 Stat. 127; Aug. 1, 1966, Pub. L. 89–523, § 2, 80 Stat. 331, related to floor stocks taxes for 1956 on tires of the type used on highway vehicles, on tread rubber, on gasoline, for 1959 on gasoline, for 1961 on certain tires and inner tubes and tread rubber, provisions relating to overpayment of floor stocks taxes, due date for taxes, taxes on certain tires and tubes, and definitions of “dealer” and “held by a dealer”. A prior section 4226 of this title was renumbered section 4227.

2 Citing Cases

Rhone-Poulenc Surfactants and Specialties, L.P.; GAF Chemicals Corporation, A Partner Other Than the Tax Matters Partner, Petitioners 114 T.C. No. 34 · 2000

Whatever force as authority - 18 - the IRM may have,16 the quoted provisions from IRM section 4226.31(13)(13) are ambiguous and unpersuasive (e.g., “The filing date of an investor’s return is the beginning of the three year IRC 6501 statute, but IRC 6229(a), at the partnership level, probably controls the partnership items even if the partnership return was filed earlier.” 4 Audit, Internal Revenue Manual (CCH), sec.

Madison Recycling Associates; David A. Beldon, Robert T. Boyd, Douglas C. Brandon, Stewart Pierce Brown, Lloyd E. Busch, David J. D'Antoni, John H.Delaney, Jr., Daniel C. Greer, Gerald O. Henderson, Charles D. Hoertz,Estate of Joseph Kessel, Thomas P. Korehle, Josiah O. Low, III, Robert J.Ripston, Howard S. Siever, Lavonne F. Siever, James W. Simpson, Jr., R.BarryUber, Lillian D. Williams, Partners Other Than The Tax Matters Partner, Petitioners T.C. Memo. 1992-605 · 1992

he partnership * * * before the Service and to perform all acts for the partnership * * * except for the execution of legally significant documents", including a period of limitations extension agreement. See 1 Audit, Internal Revenue Manual (CCH), sec. 4226.33(2), at 7233-17K. While the IRS has the authority not to accept a consent executed by an attorney-in-fact appointed by a TMP, in this case such a consent was accepted by the IRS and the consent is effective to extend the period of limitati