Washington (March 25, 2004) -- In a unanimous opinion (Galletti 4-23/04), the U.S. Supreme Court held that the Internal Revenue Service can collect unpaid employment taxes from general partners when there was a timely assessment against the partnership, even though no assessments were made against the general partners individually.

Section 6501(a) provides that, except as otherwise provided, “the amount of any tax imposed by this title shall be assessed within three years after the return was filed ... and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period.” If a tax is properly assessed within three years, the statute of limitations for the collection of the tax is extended under Section 6502(a) by 10 years from the date of assessment.

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