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1117 (4th Cir. 1977); Goldstone v. Commissioner, 65 T.C. 113
(1975).
Additional concerns are implicated where the taxpayer is a
partner and the item he seeks to change is an item that is more
appropriately determined at the partnership level. Consistent
treatment of these “partnership items” for all partners is a
central principle of the TEFRA unified partnership audit and
litigation procedures. See secs. 6221, 6222, 6227, 6231(a)(3);
H. Conf. Rept. 97-760, at 600-601 (1982), 1982-2 C.B. 600,
662-663. To help the Secretary monitor consistency and to
facilitate coordination, the statute and regulations thereunder
establish specific procedures for changing the treatment of
partnership items on a partner’s return. Sec. 6227; secs.
301.6227(b)-1T, 301.6227(c)-1T, Temporary Proced. & Admin. Regs.,
52 Fed. Reg. 6788 (Mar. 5, 1987). As an express legislative
prescription, these procedures apparently supersede the
discretionary administrative standards and case law governing the
acceptance of amended returns generally: a partner’s treatment
of partnership items on his return may not be changed except in
accordance with these procedures. Sec. 301.6221-1T(a), Temporary
Proced. & Admin. Regs., 52 Fed. Reg. 6781 (Mar. 5, 1987).
Section 6227 provides that in order to change the treatment
of a partnership item on his return the partner must file a
request for administrative adjustment (RAA). Sec. 6227(a), (c).
The RAA is filed on Form 8082, Notice of Inconsistent Treatment
or Amended Return, together with the partner’s amended Federal
income tax return. Sec. 301.6227(c)-1T, Temporary Proced.
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