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innocent spouse with respect to both the computational adjustment
relating to the partnership items and the additions to tax.
As previously indicated, respondent has filed a Motion to
Dismiss. In this motion, respondent moves to dismiss for lack of
jurisdiction and to strike those allegations set forth in the
petition that pertain to petitioner's liability for partnership
items for 1982. Respondent does not dispute that petitioner is
entitled to raise the innocent spouse defense as to the additions
to tax determined in the affected items notice of deficiency.
Discussion
In general, the tax treatment of any partnership item is
determined at the partnership level pursuant to the unified audit
and litigation procedures set forth in sections 6221 through
6231. TEFRA sec. 402(a), 96 Stat. 648. The TEFRA procedures
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.
An affected item is defined in section 6231(a)(5) as any
item to the extent that such item is affected by a partnership
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