6
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011