Leo and Pauline Goldman - Page 7

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          Naftel v. Commissioner, 85 T.C. 527, 530 (1985); Estate of Young            
          v. Commissioner, 81 T.C. 879, 880-881 (1983).  Moreover, we have            
          jurisdiction to decide whether we have jurisdiction.  Pyo v.                
          Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83           
          T.C. 309, 314 (1984).                                                       
               The tax treatment of partnership items generally is                    
          determined at the partnership level pursuant to the unified audit           
          and litigation procedures set forth in sections 6221-6233.  Tax             
          Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-           
          248, sec. 402(a), 96 Stat. 648.  The TEFRA procedures apply with            
          respect to a partnership's taxable years beginning after                    
          September 3, 1982.  Sparks v. Commissioner, 87 T.C. 1279, 1284              
          (1986); Maxwell v. Commissioner, 87 T.C. 783, 789 (1986); Alpha             
          Chemical Partners v. Commissioner, T.C. Memo. 1995-141.                     
          Partnership items include each partner's proportionate share of             
          the partnership's aggregate items of income, gain, loss,                    
          deduction, or credit.  Sec. 6231(a)(3); sec. 301.6231(a)(3)-                
          1(a)(1)(i), Proced. & Admin. Regs.                                          
               Partnership items do not include any "affected item", which            
          is defined as any item that is affected by a partnership item.              
          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 record the change in a partner's           
          tax liability resulting from the proper treatment of a                      
          partnership item.  Sec. 6231(a)(6).  After partnership level                




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