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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011