William L. and Mary Lee Powell - Page 6

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          v. Commissioner, 87 T.C. 1279, 1284 (1986).  The TEFRA procedures           
          apply to the taxable years 1982 and 1983 of Barrister Series 112.           
               An affected item is defined in 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 the proper               
          treatment of partnership items.  Sec. 6231(a)(6); White v.                  
          Commissioner, supra.  Once partnership level proceedings are                
          completed, respondent is permitted to assess a computational                
          adjustment against a partner without issuing a deficiency notice.           
          Sec. 6230 (a)(1); N.C.F. Energy Partners v. Commissioner, 89 T.C.           
          741, 744 (1987); Maxwell v. Commissioner, supra at 792 n.9.                 
               The second type of affected item is one that is dependent on           
          factual determinations to be made at the individual partner                 
          level.  N.C.F. Energy Partners v. Commissioner, supra at 744.               
          Section 6230(a)(2)(A)(i) provides that the normal deficiency                
          procedures apply to affected items that require determinations at           
          the partner level.  Additions to tax under sections 6653(a)(1)              
          and(2) and 6661 are affected items requiring factual                        
          determinations at the individual partner level and are subject to           
          the normal deficiency procedures.  N.C.F. Energy Partners v.                
          Commissioner, supra at 745.                                                 








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