- 6 - 741 (1987); Maxwell v. Commissioner, 87 T.C. 783 (1986); and Gillilan v. Commissioner, T.C. Memo. 1993-366.5 2. Partnership Items, Nonpartnership Items, Affected Items, and Computational Adjustments The terms “partnership item”, “nonpartnership item”, “affected item”, and “computational adjustment” are terms of art. They are defined in section 6231(a)(3), (4), (5), and (6), respectively, as follows: The term “partnership item” means, with respect to a partnership, any item required to be taken into account for the partnership’s taxable year under any provision of subtitle A to the extent regulations prescribed by the Secretary provide that, for purposes of this subtitle, such item is more appropriately determined at the partnership level than at the partner level. The term “nonpartnership item” means an item which is (or is treated as) not a partnership item. The term “affected item” means any item to the extent such item is affected by a partnership item. The term “computational adjustment” means the change in the tax liability of a partner which properly reflects the treatment under this subchapter of a partnership item. * * * Section 6231 is one of a group of provisions concerning the tax treatment of partnership items that was added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 5Petitioner’s alternative ground is that this proceeding is time barred by sec. 6501(a). The same ground was raised in the partnership case. See Rhone-Poulenc Surfactants & Specialties, L.P., v. Commissioner, 114 T.C. __ (2000). Because of our holding that we lack jurisdiction, we need not address petitioner’s alternative ground.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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