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information return in order to determine the amount of gross
income stated on the partnership’s information return, which in
turn is necessary in order to determine the amount of the
taxpayer partner’s gross income stated in the taxpayer’s tax
return. There does not appear to be any dispute that these other
forms, schedules, statements, and other documents of the 1st-tier
partnership’s information return are treated collectively as
adjuncts to, and part of, the taxpayer partner’s tax return for
purposes of determining the amount of gross income stated on the
taxpayer partner’s tax return, even though they are not attached
to the taxpayer partner’s tax return.
If the 1st-tier partnership’s information return discloses
net income or loss from a 2d-tier partnership, then the same
analysis requires us to consider the 2d-tier partnership’s
information return as merely another document that is an adjunct
to, and part of, the taxpayer partner’s tax return. That is, to
paraphrase the Court of Appeals for the Second Circuit (see
Estate of Klein v. Commissioner, 537 F.2d at 704), gross income
is not “stated in the return” of a taxpayer partner who reports
net partnership income from a 1st-tier partnership which in turn
reports net partnership income from a 2d-tier partnership unless
one looks at the 1st-tier partnership’s information return
together with all its adjuncts--among them being the 2d-tier
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