- 7 -
that she complied with the notice requirements set forth in
section 6223(a). Respondent complied with this directive, and
the parties ultimately stipulated to many of the facts and
documents set forth in respondent's response. Specifically, the
parties stipulated that respondent mailed petitioner an NBAP and
an FPAA in respect of respondent's examination of Computer
Graphics' 1982 taxable year.
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
item. White v. Commissioner, 95 T.C. 209, 211 (1990). There are
two types of affected items. Id.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011