Robert Michael Garner - Page 6

                                        - 6 -                                         

          Manual, Issue 45, December 20, 1992, provides that "Certified               
          mail may be addressed for delivery only * * * in the United                 
          States and its territories and possessions."  See also                      
          International Mail Manual, Issue 12, July 8, 1993, at 550.                  
                                       OPINION                                        
               For partnership taxable years beginning after September 3,             
          1982, the tax treatment of partnership items is generally                   
          determined at the partnership level, and the determination is               
          made under the unified audit and litigation procedures set forth            
          in sections 6221 through 6231.  Partnership items include each              
          partner's proportionate share of the partnership's items of                 
          income, gain, loss, deduction, or credit.  Crowell v.                       
          Commissioner, 102 T.C. 683, 688-689 (1994).  Partnership items do           
          not include "affected items"; i.e., items that are affected by              
          partnership items.  Sec. 6231(a)(5); White v. Commissioner,                 
          95 T.C. 209, 211 (1990).                                                    
               There are two types of affected items.  The first type is a            
          computational adjustment made to a partner's tax liability to               
          reflect adjustments to partnership items.  Sec. 6231(a)(6).                 
          After partnership level proceedings are completed, the                      
          Commissioner may assess computational adjustments without issuing           
          a deficiency notice.  Sec. 6230(a)(1).  The second type of                  
          affected item requires a partner level determination.  Sec.                 
          6230(a)(2)(A)(i); N.C.F. Energy Partners v. Commissioner, 89 T.C.           





Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011