Rhone Poulenc Surfactants and Specialties, L.P. - Page 61

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          includable therein which is in excess of 25 percent of the amount           
          of gross income stated in the return, etc.                                  
               In contrast, if section 6229 is the only assessment period             
          for TEFRA partnership items, the only relevant facts will be the            
          partnership-related facts.  This will result in adjustments in              
          the tax treatment of partnership items in one proceeding at the             
          partnership level, rather than in separate proceedings with the             
          partners.  Thus, interpreting section 6229(a) as it is written              
          and as Congress intended effects an entity approach that results            
          in minimizing the inconsistent and unfair treatment of the same             
          partnership item.                                                           
               Accordingly, I respectfully dissent.                                   
               CHABOT and FOLEY, JJ., agree with this dissent.                        

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