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parties to the case executed and filed a TEFRA-type decision
document to resolve that litigation.
Under TEFRA, partnership items include each partner's
proportionate share of the partnership's items of income, gain,
loss, deduction, or credit. See 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). Affected items are of two types. The first type is a
computational adjustment made to a partner's tax liability to
reflect adjustments to partnership items. See sec. 6231(a)(6).
After partnership level proceedings are completed, the
Commissioner may assess computational adjustments without issuing
a deficiency notice. See sec. 6230(a)(1). The second type of
affected item requires a partner level determination. See sec.
6230(a)(2)(A)(i); N.C.F. Energy Partners v. Commissioner, 89 T.C.
741, 744 (1987). The additions to tax for valuation
overstatement at issue are an example of the second type of
affected item; they are subject to the deficiency procedures.
See sec. 6230(a)(2)(A)(i); see also Garner v. Commissioner, T.C.
Memo. 1996-37.
The 1979 notice, 1980 notice, and 1981 notice are affected
items notices of deficiency which are subject to TEFRA’s rules
governing the period of limitation for timely assessment. The
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