CC & F Western Operations Ltd. Partnership v. Commissioner

BOUDIN, Chief Judge.

We are asked to resolve whether a tax assessment against CC & F Western Operations Limited Partnership (‘Western”) was timely filed under a provision of the Internal Revenue Code that gives the IRS three additional years to impose such an assessment on a partnership that omits a substantial amount of gross income from its return. 26 U.S.C. § 6229(c)(2) (1994). The facts, which are fully stipulated, involve the sale of real estate interests in a complicated two-step transaction.

CC & F Investment Company Limited Partnership (“CC & F Investment”) and CC & F Investors, Inc.…