11
Transpac partnership 1982-1 but not Transpac partnerships 1982-15
and 1982-21.
In a letter to Shaughnessy dated September 9, 1992,
Fensterheim stated that he had settled his interests in each
Transpac partnership, 1982-1, 1982-15, and 1982-21. Fensterheim
enclosed with his letter copies of three Forms 870-L(AD), one for
each Transpac partnership, 1982-1, 1982-15, and 1982-21.
Fensterheim's and his wife's signatures appeared on each of the
Forms 870-L(AD), but there were no signatures by respondent's
authorized representative.
In a letter to Fensterheim dated October 13, 1992, Goldbas
informed Fensterheim that duplicate settlement packages for the
Transpac partnerships 1982-15 and 1982-21 would be sent to him
and that he should execute and return them to the Andover Service
Center. Fensterheim did not execute these duplicate settlement
documents.
OPINION
Under the TEFRA provisions, the tax treatment of partnership
items is decided at the partnership level in a unified
partnership proceeding rather than separate proceedings for each
partner, Boyd v. Commissioner, 101 T.C. 365, 369 (1993), and
"affected items", items affected by the treatment of partnership
items (e.g. certain additions to tax), only can be assessed
following the conclusion of the partnership proceeding. See sec.
6225(a); Maxwell v. Commissioner, 87 T.C. 783, 791 n.6 (1986).
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