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Therefore, remittances and assessments subsequent to that date, including the March 6, remittance, the only remittance still in dispute, are untimely. As the separate partnership proceedings go, so do the statutes of limitation that govern those proceedings.

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All these had again to do with RAP-generated income. If a proceeding regarding a prime entity started the clock running on all subsidiary entities of the prime, the IRS would be required to examine all constituent entities when it examines a prime. In this instance the ground for refund may reasonably be said to be fairly comprised within the refund application. The Parmas assert that the government did not make timely assessments on income that flowed from the partnership to the corporation to the Parmas. In discussing Sentesupra, a case offered by the government, the Parmas agree that a Tax Court action may consider only those items relating to the entity in the action, and not those of other entities.

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