- 37 -
Accordingly, respondent is not precluded from making an
assessment for the taxable year 1982 after having issued a no-
change letter for that year.8
Petitioner has made other arguments that we have considered
in reaching our decision. To the extent that we have not
discussed these arguments, we find them to be without merit.
To reflect our disposition of the disputed issues, as well
as the parties' stipulation of settled issues,
Decisions will be entered
for petitioner Bernice M. Ulanoff
and for respondent as to petitioner
Stanley M. Ulanoff.
8 In addition, we note that at issue for 1982 are so-called
affected items consisting of additions to tax for negligence and
overvaluation. See N.C.F. Energy Partners v. Commissioner, 89
T.C. 741, 744-746 (1987). The TEFRA procedures, codified at
secs. 6221 through 6233, segregate adjustments attributable to an
individual's interest in a partnership from all other adjustments
to the individual's return. See Maxwell v. Commissioner, 87 T.C.
783, 787-788 (1986). Respondent's examination of petitioner's
individual return for 1982 would therefore not have focused on
affected items.
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