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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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Last modified: May 25, 2011