it would appear that the trial court was right in holding the assessment was insufficient for failure to comply with the statutory requirements. Id. at 464 (emphasis added). In summary, we hold that the assessment of tax liability against the Partnership, without more, does not allow the IRS to collect those taxes directly from the individual partners. B. California Partnership Law In an attempt to avoid the time-bar on assessments, the IRS argues in the alternative that it was not requir t of the Partnership that the IRS has a right to collect against it, the IRS asserts that it may bring an action under state law to obtain a judgment holding Debtors responsible for the unpaid taxes. Cal. Corp.Code § 16307(b); see also Remington v. United States, 210 F.3d 281, 282-83 (5th Cir.2000) (<HOLDING>); United States v. W. Prods., Ltd., 168
holding that general partners must notify limited partners of partnership opportunity to purchase adjacent property but not addressing whether  9404 requires affirmative consent of partners after such notice holding that under the texas uniform partnership act the government was entitled to collect the  tax liability indisputably a partnership debt from any one of the general partners holding that under texas law limited partner could not bring breach of fiduciary duty claims without the partnership because the partners claims would be indirect and duplicative of the partnerships claims holding only a party to the partnership agreement can breach it and be liable for a breach of fiduciary duty relating to partnership obligations holding that under california law partners are personally liable for the debts and liabilities of the partnership including its tax liability