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TEFRA adjustments are of two varieties: Partnership item
adjustments and affected item adjustments. Section 6231(a)(3)
defines a partnership item as follows:
SEC. 6231(a)(3) Partnership item.--
The term "partnership item" means, with respect to a
partnership, any item required to be taken into account
for the partnership's taxable year under any provision
of subtitle A to the extent regulations prescribed by
the Secretary provide that, for purposes of this
subtitle, such item is more appropriately determined at
the partnership level than at the partner level.
Such items include items of income, gain, loss, deduction or
credit of the partnership, and each partner's share thereof.
Sec. 301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs.
The term "affected item" is defined as "any item to the
extent such item is affected by a partnership item." Sec.
6231(a)(5); see White v. Commissioner, supra at 211; Maxwell v.
Commissioner, supra at 790-791.
The term "nonpartnership item" means an item which is (or is
treated as) not a partnership item. Sec. 6231(a)(4).
Partnership item adjustments can be made to an individual's
return solely through computational adjustments. Sec. 6230(a).
Affected item adjustments, on the other hand, can be made either
through computational adjustments or deficiency proceedings,
depending on the nature of the particular affected item. Sec.
6230(a); Brookes v. Commissioner, 108 T.C. 1, 5-6 (1997); Jenkins
v. Commissioner, 102 T.C. 550, 554 (1994); N.C.F. Energy Partners
v. Commissioner, supra at 744-745. If there are no partner-level
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