- 12 - partnership that are subject to TEFRA from all other adjustments that can be made to the individual's return. See Maxwell v. Commissioner, 87 T.C. 783, 787-788 (1986). Agent Coar was therefore restricted from examining affected items as part of petitioner's individual tax case. See id. In view of this fact, the "total" adjustments Agent Coar could make to petitioner's 1982 taxable year would necessarily exclude any adjustments for affected items. Thus, any representation by Agent Coar must be viewed in the context of Agent Coar's limited authority and the restricted scope of his examination. In light of the foregoing, the execution of Form 4549 with respect to the 1982 year did not preclude respondent from subsequently issuing an affected items notice of deficiency for the same taxable year. To reflect our disposition of the disputed issue, as well as the parties' stipulation of settled issues, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011