- 7 - at 600 (1982), 1982-2 C.B. 600, 662. Consequently, the portion of any deficiency attributable to partnership items cannot be considered in a partner's personal case and must be considered solely in a partnership proceeding. Secs. 6221, 6226(a); Maxwell v. Commissioner, supra at 788. Thus, we lack jurisdiction to redetermine a deficiency attributable to partnership items in a partner-level proceeding involving nonpartnership items. Powell v. Commissioner, 96 T.C. 707, 712 (1991); Woody v. Commissioner, 95 T.C. 193, 208 (1990); Saso v. Commissioner, 93 T.C. 730, 734 (1989); Maxwell v. Commissioner, supra at 788. Section 6231(a)(3) defines a "partnership item" as any item required to be taken into account for the partnership's taxable year to the extent that the Secretary provides by regulations that the item is more appropriately determined at the partnership level than at the partner level. N.C.F. Energy Partners v. Commissioner, 89 T.C. 741, 743 (1987). Partnership items include each partner's proportionate share of the partnership's aggregate income, gain, loss, deduction, or credit. Sec. 6231(a)(3); sec. 301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs. “Affected items” are nonpartnership items, defined in Crowell v. Commissioner, 102 T.C. 683, 689 (1994), as follows: Affected items are defined under section 6231(a)(5) as any item to the extent such item is affected by a partnership item. White v. Commissioner, 95 T.C. 209, 211 (1990). The first type of affected item is a computational adjustment made to record the change in a partner’s tax liability resulting from adjustments reflecting the proper treatment ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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