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mailed their petition on October 16, 1998, and it was filed on
October 20, 1998. The petition was, therefore, not timely filed
if section 6213(a) applies.
Petitioners argue, however, that section 6213(a) is
inapplicable in this case. According to petitioners, since
respondent's determinations in the notice of deficiency arose
from adjustments relating to their partnership interest in
Executive Inn, the extended time for filing a petition under
section 6226(b)(1) of the partnership audit and litigation
procedures, secs. 6221-6233, enacted in 1982 as part of the Tax
Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-
248, sec. 402(a), 96 Stat. 648 (TEFRA partnership procedures),
governs the time period for filing the petition.
Under the TEFRA partnership procedures, "the tax treatment
of any partnership item shall be determined at the partnership
level." Sec. 6221. "A partner's treatment of partnership items
on the partner's return may not be changed except as provided in
sections 6222 through 6231 of the Code and the regulations
thereunder." Sec. 301.6221-1T(a), Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 6779, 6781 (Mar. 5, 1987). The TEFRA
partnership procedures were designed to "provide a method for
uniformly adjusting items of partnership income, loss, deduction,
or credit that affect each partner." Harrell v. Commissioner, 91
T.C. 242, 243 (1988). "Congress decided that no longer would a
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