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of gross income anywhere on the tax return.7 As a result, we
must look through the various forms, etc., attached to the
taxpayer’s basic tax return form in order to identify the
components of gross income that must be added together in order
to determine the total amount of gross income stated in the
taxpayer’s tax return. It has long been accepted that, for these
purposes, the information return of the taxpayer’s properly
identified 1st-tier partnership is treated as part of the
taxpayer’s tax return. But the 1st-tier partnership’s
information return suffers from the same “defect” in that we must
look through the various forms, etc., attached to the 1st-tier
partnership’s information return in order to identify the
components of gross income that must be added together in order
to determine the total amount of gross income stated in the 1st-
tier partnership’s information return. Every explanation that
has been drawn to our attention, or that we have discovered, as
to why we must treat the properly identified 1st-tier
partnership’s information return as part of the taxpayer’s tax
return applies with equal force to treating the properly
identified 2d-tier partnership’s information return as part of
the 1st-tier partnership’s information return.
Accordingly, we agree with petitioners’ conclusion.
7As is the case in the Harlan’s docket, even if the taxpayer
does state such an amount and clearly labels it as such, that may
not be the correct amount for purposes of sec. 6501(e)(1)(A),
even if it is the correct amount for other purposes.
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