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2 C.B. 667. As noted above, partners in simple partnerships,
like petitioners, resolve their "own tax responsibilities
separately as [individuals] with the IRS", McKnight v.
Commissioner, 99 T.C. at 185; see Tax Compliance Act of 1982 and
Related Legislation: Hearings on H.R. 6300 Before the House
Committee on Ways and Means, 97th Cong., 2d Sess. 260 (1982)
(Statement of John S. Nolan, Chairman, Section of Taxation,
American Bar Association).
Furthermore, petitioners had the right, which they have
attempted to exercise in this case, to challenge respondent's
determinations resulting from modifications to partnership income
by filing a petition for redetermination within 90 days of the
mailing of the notice of deficiency. See sec. 6213(a).
Petitioners have only themselves to blame for the fact that we
lack jurisdiction over this matter because of their untimely
filing.
Petitioners further argue that the provisions of subchapter
K (sections 701 through 761) and the definitions set forth in
section 7701(a)(2) (defining the terms "Partnership and Partner")
and (14) (defining the term "Taxpayer") somehow mandate the
application of the TEFRA partnership procedures in this case. As
noted above, the TEFRA partnership procedures "provide a method
for uniformly adjusting items of partnership income, loss,
deduction, or credit that affect each partner". Harrell v.
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