Robert H. Avellini - Page 19

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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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