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administrative resolution of the partner's tax liability and
cannot be the subject of a partnership proceeding. See, e.g.,
Maxwell v. Commissioner, 87 T.C. 783, 788-789 (1986).
Petitioner has made various arguments based on an assumption
that respondent included partners who have accepted the out-of-
pocket settlement in her calculations on which the proposed
decision documents are based. Petitioner bears the burden of
proof in these cases. Rule 142. We begin by noting that there
is no evidence in the record concerning partners who have
accepted the out-of-pocket settlement. Therefore, we have no
indication that any such partners were included in respondent's
calculations. We will, however, further address petitioner's
arguments.
Petitioner argues that the partnership income, losses,
credits, and liabilities calculated pursuant to the settlement
agreement should be allocated to a limited group of partners.
Petitioner contends that any partners who have accepted the out-
of-pocket settlement offer from respondent are not parties to
this proceeding pursuant to section 6226. Therefore, petitioner
argues, the Court is prohibited from allocating partnership items
to those partners because we do not have jurisdiction to do so.
Petitioner also argues that pursuant to section 6231, the
partnership items of the partners who have accepted the out-of-
pocket settlement have been converted to nonpartnership items.
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