12
Enclosed is my Power of Attorney. Please see that
all further communication with the taxpayer regarding
this matter is made through me.
Respondent's authorized representative executed the Form
870-L(AD) on December 6, 1991. Respondent assessed deficiencies
in income taxes attributable to the settlement of the Valley
Cable partnership items on December 3, 1992, as to the Rays'
taxable years 1983 and 1984. Respondent assessed a deficiency in
income tax attributable to the settlement of the Valley Cable
partnership items on December 4, 1992, as to the Dominguezes'
taxable year 1983. Respondent issued notices of deficiency dated
December 4, 1992, determining additions to tax attributable to
the Rays for the taxable years 1983 and 1984. Respondent issued
a notice of deficiency dated December 4, 1992, determining
additions to tax attributable to the Dominguezes for the taxable
year 1983.
On January 10, 1994, the Rays and Dominguezes each made a
payment in the amount of $5,000 to respondent, which was
designated as a payment of income tax for the taxable year 1983.
OPINION
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
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