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in sections 6221 through 6233. Tax Equity & Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a),
96 Stat. 648. Pursuant to the TEFRA provisions, which apply with
respect to all taxable years of a partnership beginning after
September 3, 1982, the tax treatment of any partnership item
generally is determined in a single proceeding at the partnership
level. Sparks v. Commissioner, 87 T.C. 1279, 1284 (1986);
Maxwell v. Commissioner, 87 T.C. 783, 789 (1986).
Partnership items include each partner's proportionate share
of the partnership's aggregate items of income, gain, loss,
deduction, or credit. Sec. 6231(a)(3); sec. 301.6231(a)(3)-
1(a)(1)(i), Proced. & Admin. Regs.
Partnership items are distinguished from affected items
which are 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, the Commissioner 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.
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