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Manual, Issue 45, December 20, 1992, provides that "Certified
mail may be addressed for delivery only * * * in the United
States and its territories and possessions." See also
International Mail Manual, Issue 12, July 8, 1993, at 550.
OPINION
For partnership taxable years beginning after September 3,
1982, the tax treatment of partnership items is generally
determined at the partnership level, and the determination is
made under the unified audit and litigation procedures set forth
in sections 6221 through 6231. Partnership items include each
partner's proportionate share of the partnership's items of
income, gain, loss, deduction, or credit. Crowell v.
Commissioner, 102 T.C. 683, 688-689 (1994). Partnership items do
not include "affected items"; i.e., items that are affected by
partnership items. Sec. 6231(a)(5); White v. Commissioner,
95 T.C. 209, 211 (1990).
There are two types of affected items. The first type is a
computational adjustment made to a partner's tax liability to
reflect adjustments to partnership items. Sec. 6231(a)(6).
After partnership level proceedings are completed, the
Commissioner may assess computational adjustments without issuing
a deficiency notice. Sec. 6230(a)(1). The second type of
affected item requires a partner level determination. Sec.
6230(a)(2)(A)(i); N.C.F. Energy Partners v. Commissioner, 89 T.C.
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Last modified: May 25, 2011