- 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37
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