Lawrence V. and Katharine T. Brookes - Page 7

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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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