Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 23




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          Respondent answers that petitioner has standing only to ask                 
          redress of violations of rights that he holds in his capacity as            
          TMP and a partner of the partnership.  Essentially, we agree with           
          respondent.  On the question of standing, see Dixon v.                      
          Commissioner, 90 T.C. 237, 243-244 (1988).  Respondent’s                    
          question, however, suggests a more fundamental issue, viz, the              
          limits of our subject matter jurisdiction in this case.                     
               B.  Limited Jurisdiction To Redetermine Partnership Items              
               This is a case brought pursuant to section 6226 for the                
          redetermination of certain partnership items.  Section 6226 is a            
          part of subchapter C, chapter 63, subtitle F of the Code                    
          (subchapter C).  Subchapter C comprises sections 6221 through               
          6233.  Subchapter C was added to the Code by the Tax Equity &               
          Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248,                  
          sec. 402(a), 96 Stat. 324, 648.  Congress added subchapter C to             
          the Code for the purpose of changing prior law, under which the             
          Federal income tax consequences of partnership operations were              
          determined at the partner level, generally in a separate                    
          proceeding with respect to each partner.  See H. Conf. Rept. 97-            
          760, at 599 (1982), 1982-2 C.B. 600, 662 (conference report                 
          accompanying H.R. 4961, 97th Cong., 2d Sess. (1982), which, when            
          enacted, became TEFRA).  In general, subchapter C provides that             
          the tax treatment of partnership items will be determined at the            
          partnership level in a unified partnership proceeding rather than           






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