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income tax return. Judicial review of respondent's deficiency
determination was restricted to the particular partner before the
Court.
The Tax Equity and Fiscal Responsibility Act of 1982
(TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648, enacting
the Tax Treatment of Partnership Items Act of 1982, changed this
procedure. Under the TEFRA partnership audit and litigation
procedures, Congress provided a method that did not determine a
partner's tax liability on an individual basis: "The tax
treatment of any partnership item shall be determined at the
partnership level." Sec. 6221. The provisions of TEFRA,
however, are effective only for partnership years beginning after
its date of enactment, September 3, 1982, and to any partnership
year ending after that date if the partnership, each partner, and
each indirect partner requests such application and the Secretary
or his delegate consents to such application. TEFRA sec. 407, 96
Stat. 670-671
All of the settlement agreements signed by petitioners
contain a statement that they are entered into under the
provisions of section 6224(c).5 Under section 6224(c)(1), a
settlement agreement is binding on the parties to the agreement
5Sec. 6224(c) is part of the Tax Treatment of Partnership
Items Act of 1982 in TEFRA, Pub. L. 97-248, 96 Stat. 648-669,
enacting secs. 6221-6232.
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Last modified: May 25, 2011