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sec. 402(a), 96 Stat. 648. The TEFRA provisions apply generally
to partnerships for all taxable years beginning after September
3, 1982. Sparks v. Commissioner, 87 T.C. 1279, 1284 (1986).
Under the TEFRA provisions, the tax treatment of partnership
items is decided at the partnership level in a unified
partnership proceeding rather than separate proceedings for each
partner, Boyd v. Commissioner, 101 T.C. 365, 369 (1993), and
"affected items", items affected by the treatment of partnership
items (e.g. certain additions to tax), can only be assessed
following the conclusion of the partnership proceeding. See sec.
6225(a); Maxwell v. Commissioner, 87 T.C. 783, 791 n.6 (1986).
The question whether we have jurisdiction to determine an
overpayment attributable to partnership items in a proceeding for
redetermination of deficiencies attributable to nonpartnership
items has been decided in a case involving a plastics recycling
partnership. Trost v. Commissioner, 95 T.C. 560 (1990). In a
case involving circumstances much like those in the present case,
this Court held that the portion of any deficiency attributable
to partnership items cannot be considered in the partner's
personal case. Id. at 563.
In the present case, respondent determined deficiencies in
petitioner's income taxes for 1981 and 1982. Petitioner filed a
petition for review of respondent's deficiency determinations and
claimed therein that benefits flowed through to him from a TEFRA
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