- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011