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proceedings; and (6) respondent's actions during the TEFRA
proceedings constituted a fraud upon the Court.
Discussion
The tax treatment of Hamilton was determined at the
partnership level pursuant to the TEFRA partnership provisions in
sections 6221 through 6233. The partnership audit provisions
provide a unified partnership proceeding for determination of the
tax treatment of partnership items separate from and independent
of a partner's deficiency proceeding involving nonpartnership
items. See Tax Equity and Fiscal Responsibility Act of 1982
(TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648; Brookes v.
Commissioner, 108 T.C. 1, 5 (1997); Maxwell v. Commissioner, 87
T.C. 783, 787-788 (1986). Accordingly, this Court does not have
jurisdiction in a partner's personal tax case to redetermine any
portion of a deficiency attributable to partnership items. See
sec. 6221; Brookes v. Commissioner, supra at 5; Maxwell v.
Commissioner, supra at 788.
A partnership item is defined as any item required to be
taken into account for the partnership's taxable year to the
extent that the Secretary provides by regulations that the item
is more appropriately determined at the partnership level than at
the partner level. See sec. 6231(a)(3); Brookes v. Commissioner,
supra at 5; N.C.F. Energy Partners v. Commissioner, 89 T.C. 741,
743 (1987). Partnership items include each partner's
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