Meserve Drilling Partners, Regional Resources, Inc., F.K.A. R&R Energy, Inc., Tax Matters Partner - Page 5

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          provisions were enacted partly in response to the administrative            
          problems experienced by the Internal Revenue Service in auditing            
          returns of partnerships, particularly tax shelter partnerships              
          with numerous partners.  Staff of Joint Comm. on Taxation,                  
          General Explanation of the Revenue Provisions of the Tax Equity             
          and Fiscal Responsibility Act of 1982, at 268 (J. Comm. Print               
          1982).  As we stated in an earlier case interpreting the TEFRA              
          partnership provisions:                                                     
                    By enacting the partnership and audit litigation                  
               procedures, Congress provided a method for uniformly                   
               adjusting items of partnership income, loss, deduction,                
               or credit that affect each partner.  Congress decided                  
               that no longer would a partner's tax liability be                      
               determined uniquely but "the tax treatment of any                      
               partnership item [would] be determined at the                          
               partnership level."  Sec. 6221.  [Maxwell v.                           
               Commissioner, 87 T.C. 783, 787 (1986); alteration in                   
               original.]                                                             
               Section 6221 provides that the tax treatment of partnership            
          items shall be determined at the partnership level, except as               
          otherwise provided in subchapter C of chapter 63 of the Code.               
          Section 6231(a)(3) provides that a "partnership item" means any             
          item required to be taken into account for the partnership's                
          taxable year under any provision of subtitle A of the Code to the           
          extent prescribed by the regulations as an item that "is more               
          appropriately determined at the partnership level than at the               
          partner level."  Section 6231(a)(4) defines "nonpartnership                 
          items" as those items that are not partnership items.                       







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