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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 determine whether we have jurisdiction. Pyo v.
Commissioner, 83 T.C. 626, 632 (1984); Kluger v. Commissioner, 83
T.C. 309, 314 (1984).
In a partnership action for readjustment of partnership
items, this Court has jurisdiction when the Commissioner has
mailed a valid FPAA and the tax matters partner or other eligible
partner has timely filed a petition with the Court seeking a
readjustment of partnership items. Sec. 6226; Rule 240(c). If
the FPAA is not valid, we lack subject matter jurisdiction.
Clovis I v. Commissioner, 88 T.C. 980 (1987); Maxwell v.
Commissioner, 87 T.C. 783, 788-789 (1986).
At a minimum, the FPAA must give notice to the taxpayer that the
Commissioner has finally determined adjustments to the
partnership return. Chomp Associates v. Commissioner, 91 T.C.
1069, 1073-1074 (1988); Clovis I v. Commissioner, supra at 982.
Petitioner's argument as to jurisdiction turns on section
301.6231(a)(3)-1(a), Proced. & Admin. Regs, which defines
"partnership items". The unified audit and litigation procedures
applicable to partnership items, which are found in sections
6221-6233, were enacted as part of the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401(a),
96 Stat. 648, and are effective for partnership taxable years
commencing after September 3, 1982. The TEFRA partnership
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