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partnership for 1982. Petitioner further urges that he entered
into a stipulation of agreed adjustments with respect to 1982 and
that in such stipulation in petitioner's individual case,
petitioner and respondent resolved issues concerning partnership
items. As this Court has stated in Maxwell v. Commissioner,
supra, and Trost v. Commissioner, supra, we do not have
jurisdiction to consider petitioner's claims with respect to
partnership items because this case only involves nonpartnership
items.
This Court has limited jurisdiction and may only exercise
jurisdiction to the extent expressly permitted by statute. Trost
v. Commissioner, supra at 565, Judge v. Commissioner, 88 T.C.
1175, 1180-1181 (1987). Accordingly, contrary to petitioner's
arguments, we do not have jurisdiction over the TEFRA partnership
items for 1982 in these proceedings. Those matters have been
considered at the partnership level in Dickinson, etc., and are
not subject to modification in these proceedings at the partner
level.
We note also that, in these proceedings, respondent has
established that the Detroit docket attorney in charge of the
nonplastics issue here had no authority to enter into an
agreement with respect to plastics issues. There is no evidence
in this case that he intended to go beyond his authority. Nor is
there any convincing evidence that petitioner's counsel, an
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