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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.
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