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from Mr. Redding, the Goodwins did not sign and return the
closing agreement by the deadline set forth in the letter.
OPINION
The Tax Court is a Court of limited jurisdiction and may
exercise jurisdiction only to the extent expressly permitted by
statute. See sec. 7442; Trost v. Commissioner, 95 T.C. 560, 565
(1990). We have jurisdiction to decide whether we have
jurisdiction. Pyo v. Commissioner, 83 T.C. 626, 632 (1984).
Section 6226(f) vests this Court with subject matter jurisdiction
to determine all partnership items of the partnership for the
partnership taxable year to which the FPAA relates and the proper
allocation of such items among the partners.9 This Court's
jurisdiction over a partnership action is predicated upon the
mailing of a valid FPAA by the Commissioner to the TMP and the
timely filing by the TMP or other eligible partner of a petition
seeking a readjustment of partnership items. Rule 240(c);
Seneca, Ltd. v. Commissioner, 92 T.C. 363, 365 (1989), affd.
without published opinion 899 F.2d 1225 (9th Cir. 1990). Neither
9
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. Nonpartnership items are
items that are not partnership items. Sec. 6231(a)(4). An
affected item is any item to the extent such item is affected by
a partnership item. Sec. 6231(a)(5); sec. 301.6231(a)(5)-1T(a),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5,
1987). Some affected items are subject to the deficiency
procedures contained in secs. 6211 through 6215.
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