- 5 - penalty prescribed in section 6662(a). We disagree. Although the Court's jurisdiction in a partnership proceeding is contingent on the issuance of a valid FPAA and a timely-filed petition for readjustment, see Transpac Drilling Venture 1982-22 v. Commissioner, 87 T.C. 874 (1986), the FPAA does not define the scope of the Court's jurisdiction. See, e.g., Powell v. Commissioner, 96 T.C. 707, 712-713 (1991). Rather, as previously stated, the Court's jurisdiction is prescribed by statutory provisions, to which we now turn. The Court's jurisdiction to review adjustments to a partnership return is governed by the unified partnership audit and litigation procedures set forth in sections 6221 through 6234. See Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648. Pursuant to the TEFRA provisions, which apply with respect to all taxable years of a partnership beginning after September 3, 1982, the tax treatment of any partnership item generally is determined in a single proceeding at the partnership level. See Sparks v. Commissioner, 87 T.C. 1279, 1284 (1986); Maxwell v. Commissioner, 87 T.C. 783, 789 (1986); see also sec. 6226(f). Partnership items include each partner's proportionate share of the partnership's aggregate items of income, gain, loss, deduction, or credit. See sec. 6231(a)(3); sec. 301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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