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proportionate share of the partnership's aggregate income, gain,
loss, deduction, or credit. See sec. 301.6231(a)(3)-1(a)(1)(i),
Proced. & Admin. Regs.
An affected item is defined in section 6231(a)(5) as any
item to the extent such item is affected by a partnership item.
See Brookes v. Commissioner, supra at 5; Crowell v. Commissioner,
102 T.C. 683, 689 (1994). The first type of affected item is a
computational adjustment that is made to record the change in a
partner's tax liability resulting from the proper treatment of
partnership items. See id. Once the partnership level
proceedings are completed, respondent is permitted to assess a
computational adjustment against a partner without issuing a
deficiency notice. See sec. 6230(a)(1); Brookes v. Commissioner,
supra at 5.
The second type of affected item is one that is dependent
upon factual determinations that are made at the individual
partner level. See Brookes v. Commissioner, supra at 5.
Additions to tax for negligence and valuation overstatement are
affected items requiring factual determinations at the individual
partner level. See N.C.F. Energy Partners v. Commissioner, supra
at 745. Section 6230(a)(2)(A)(i) provides that the normal
deficiency procedures apply to those affected items which require
partner level determinations.
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Last modified: May 25, 2011