§622

By expressly permitting the partner to raise this issue pursuant to section 6226(b), the statute thereby effectively treats it as a partnership item within the meaning of section 6226(b)(1) .

in the (continued. . .) was designated the TMP of Devonian in a.ccordance .with .section 301 .6231(a) .(7)-1(c), Proced, & Admin . Regs ., and timely mailed its petition to the Court with .respect to theFPAA within the 90- day period prescribed by section 622 .6(a) . Respondent's motion to dismiss for lack of jurisdiction hinges, on whether Basin was a 'general partner of Devonian during 1999 . If Basin was a general partner, then respondent's motion to dismiss for lack of jurisdiction should b

However, section 622 (c)(2) provides that if any partnership omits from gross income n amount properly includable therein that is in excess of 5 percent of the amount of gross income stated in its return, th period described in section 6229(a) is extended to 6 years .