- 7 -
Naftel v. Commissioner, 85 T.C. 527, 530 (1985); Estate of Young
v. Commissioner, 81 T.C. 879, 880-881 (1983). Moreover, we have
jurisdiction to decide whether we have jurisdiction. Pyo v.
Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83
T.C. 309, 314 (1984).
The tax treatment of partnership items generally is
determined at the partnership level pursuant to the unified audit
and litigation procedures set forth in sections 6221-6233. Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-
248, sec. 402(a), 96 Stat. 648. The TEFRA procedures apply with
respect to a partnership's taxable years beginning after
September 3, 1982. Sparks v. Commissioner, 87 T.C. 1279, 1284
(1986); Maxwell v. Commissioner, 87 T.C. 783, 789 (1986); Alpha
Chemical Partners v. Commissioner, T.C. Memo. 1995-141.
Partnership items include each partner's proportionate share of
the partnership's aggregate items of income, gain, loss,
deduction, or credit. Sec. 6231(a)(3); sec. 301.6231(a)(3)-
1(a)(1)(i), Proced. & Admin. Regs.
Partnership items do not include any "affected item", which
is defined as any item that is affected by a partnership item.
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 record the change in a partner's
tax liability resulting from the proper treatment of a
partnership item. Sec. 6231(a)(6). After partnership level
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011