- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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