- 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 than
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011