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capital account, only upon complete liquidation of all
Partnership assets, less any amount of future unpaid
assessments.
The partnership agreement was amended in February 1987.
Under the amended agreement, Shorthorn Genetic Engineering 1984-5
was reformed as Shorthorn Genetic Engineering 1984-5, J.V., and
the partnership was to operate as a general partnership under the
laws of the State of Nevada.
OPINION
Given the disposition of the issue on the merits discussed
below, we do not find it necessary to address respondent's
motions for summary judgment, and they will be denied.
When a petition for readjustment of partnership items has
been filed properly, this Court has jurisdiction to decide all of
the partnership items of the partnership and the proper
allocation of these items to the partners for the partnership
taxable year at issue. Sec. 6226(f). Partnership items are
those items required to be taken into account for the
partnership's taxable year under subtitle A which are to the
extent provided by the regulations "more appropriately determined
at the partnership level than at the partner level." Sec.
6231(a)(3). The regulations provide that such items include:
(1) The partnership aggregate and each partner's share
of each of the following:
(i) Items of income, gain, loss, deduction, or credit
of the partnership;
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