Michael J. Heckler, a.k.a. Michael Vonheckler and Charlotte A. Miska - Page 9

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          apply with respect to all taxable years of a partnership                    
          beginning after September 3, 1982.  Sparks v. Commissioner, 87              
          T.C. 1279, 1284 (1986); Maxwell v. Commissioner, 87 T.C. 783, 789           
          (1986).  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.                                          
          Affected items are defined in section 6231(a)(5) as any item                
          to the extent such item is affected by a partnership item.  White           
          v. Commissioner, supra at 211.  The first type of affected item             
          is a computational adjustment made to record the change in a                
          partner's tax liability resulting from the proper treatment of              
          partnership items.  Sec. 6231(a)(6); White v. Commissioner,                 
          supra.  Once partnership level proceedings are completed,                   
          respondent is permitted to assess a computational adjustment                
          against a partner without issuing a deficiency notice.  Sec.                
          6230(a)(1); N.C.F. Energy Partners v. Commissioner, 89 T.C. 741,            
          744 (1987);  Maxwell v. Commissioner, supra at 792 n.9.                     
          The second type of affected item is one that is dependent                   
          upon factual determinations to be made at the individual partner            
          level.  N.C.F. Energy Partners v. Commissioner, supra at 744.               
          Section 6230(a)(2)(A)(i) provides that the normal deficiency                
          procedures apply to those affected items which require partner              
          level determinations.  The additions to tax for negligence are              





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