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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.
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