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proceedings for determining deficiencies attributable to
nonpartnership items. Secs. 6221, 6230(a). The conference
report, H. Conf. Rept. 97-760, at 611 (1982), 1982-2 C.B. 600,
668, states:
Existing rules relating to administrative and
judicial proceedings, statutes of limitations,
settlements, etc., will continue to govern the
determination of a partner's tax liability attributable
to nonpartnership income, loss, deductions, and
credits. Neither the Secretary nor the taxpayer will
be permitted to raise nonpartnership items in the
course of a partnership proceeding nor may partnership
items, except to the extent they become nonpartnership
items under the rules, be raised in proceedings
relating to nonpartnership items of a partner.
In Maxwell v. Commissioner, supra at 787-788, we examined
the legislative history and statutory pattern of the TEFRA
provisions and stated:
the portion of any deficiency attributable to a
"partnership item" cannot be considered in the
partner's personal case involving other matters that
may affect his income tax liability. The "partnership
items" must be separated from the partner's personal
case and considered solely in the partnership
proceeding. * * *
In this transferee liability case, as in a proceeding for
redetermination of a deficiency, we lack jurisdiction to
adjudicate the decedent's liability for the computational
adjustment.
Petitioner argues that her receipt of an Estate Tax Closing
Letter showing no tax due with regard to the decedent's estate
tax return precludes respondent from issuing a notice of
transferee liability in regard to the liability arising from the
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