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confusing”. Foxman v. Commissioner, 41 T.C. 535, 551 n.9 (1964),
affd. 352 F.2d 466 (3d Cir. 1965).
Subtitle F of the Code is concerned with procedure and
administration. Both section 6229 and section 6501 are contained
in subtitle F. Section 6229 is one of a group of provisions
concerning the tax treatment of partnership items that was added
to the Code by TEFRA. For income tax purposes, partnerships are
not taxable entities (see section 701, which reflects the view
that a partnership is no more than an aggregation of its
members). Any income tax attributable to partnership items is
assessed at the partner level. Thus, any statute of limitations
provisions that limit the time period within which assessment can
be made are restrictions on the assessment of a partner’s tax.
Before TEFRA, adjustments with respect to partnership items
were made to each partner’s income tax return at the time (and
if) that return was examined. See H. Conf. Rept. 97-760, at 599
(1982), 1982-2 C.B. 600, 662. An administrative settlement or
judicial determination of a disagreement between a partner (or
partners) and the Commissioner bound only the parties thereto and
did not bind other partners or bind the Commissioner with respect
to other partners. See id. The tax writing committees explained
the TEFRA partnership provisions as follows: “[T]he tax
treatment of items of partnership income, loss, deductions, and
credits will be determined at the partnership level in a unified
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