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Background
Some of the facts have been stipulated, and they are so
found.
In 1982, petitioner was a partner with a 1.2374-percent
interest in a partnership known as Computer Graphics Partners,
Ltd. Pacific (Computer Graphics). On his income tax return for
1982, petitioner deducted his distributive share of the loss
claimed by Computer Graphics on its partnership return for that
year.
Computer Graphics was formed after September 3, 1982.
Accordingly, the examination of Computer Graphics' 1982 taxable
year was required to be made, and was in fact made, pursuant to
the unified partnership audit and litigation procedures set forth
in sections 6221 through 6231.1 Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 324, 648.
The Partnership Proceeding
In January 1985, and pursuant to section 6223(a)(1),
respondent mailed petitioner a notice of beginning of
administrative proceeding (NBAP) regarding the examination of
Computer Graphics' partnership return for 1982. Pursuant to
1 Unless otherwise indicated, all section, subchapter, and
chapter references in this Opinion are to the Internal Revenue
Code, as amended.
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