Bernice M. and Stanley M. Ulanoff - Page 37




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               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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