- 23 - 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 thanPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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