First Blood Associates, Richard M. Greenberg, Tax Matters Partner, et al. - Page 10

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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.                  
               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           

                    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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