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for 1982 and that the related notice of deficiency was not an
affected items notice of deficiency. Petitioners assert that the
period of limitation for assessment under TEFRA is inapplicable.
We disagree with petitioners’ arguments. First, the
proceeding in this Court involving Catamount was a TEFRA
proceeding. For partnership taxable years beginning after
September 3, 1982, the tax treatment of partnership items is
generally determined at the partnership level, and determinations
are made under the unified audit and litigation procedures set
forth in sections 6221 through 6231; i.e., the TEFRA partnership
provisions. See TEFRA sec. 407(a)(1), 96 Stat. 670. Under TEFRA
section 407(a)(3), 96 Stat. 670, the TEFRA procedures may also
apply to partnership taxable years beginning before the September
3, 1982, effective date. TEFRA section 407(a)(3) provides that
the TEFRA procedures also apply “to any partnership taxable year
* * * [ending after September 3, 1982,] if the partnership, each
partner, and each indirect partner requests such application and
the Secretary of the Treasury or his delegate consents to such
application.” Such early application of TEFRA was the case here,
where the parties to the Catamount litigation treated that case
as a TEFRA proceeding. In addition to the fact that respondent’s
audit of Catamount was followed by the issuance of an FPAA, a
petition contesting adjustments in that FPAA was filed with this
Court through and in the name of Catamount’s TMP, and both
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