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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 of
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