Asa Investerings Partnership, Alliedsignal, Inc., Tax Matters Partner - Page 6




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               Our jurisdiction over the issues decided in ASA Investerings           
          Pship. v. Commissioner, supra, was predicated on the issuance of            
          a notice of a final partnership administrative adjustment (FPAA)            
          and a petition for a readjustment of partnership items.5  See               
          sec. 6226(a).  Our decision was based on an application of the              
          unified partnership procedures.6                                            
               Petitioner contends that “there are a number of ‘affected              
          items which require partner level determinations’ (Code, Section            
          6230(a)(2)(A)(i)) with respect to which tax and, necessarily,               
          interest must have been assessed as a result of this Court’s                
          decision in this matter.”  Petitioner points to AlliedSignal’s              
          basis in ASA Investerings Partnership and the determination of an           
          appropriate amount of interest expense under section 1.861-8,               
          Income Tax Regs., as affected items that require partner-level              
          determination under section 6230(a)(2)(A)(i).  Petitioner claims            
          that “The assessment(s) with respect to these ‘affected items,’             
          pursuant to the provisions of Code, Section 6230(a)(2)(A)(i) of             




               5In ASA Investerings Pship. v. Commissioner, T.C. Memo.                
          1998-305, affd. 201 F.3d 505 (D.C. Cir. 2000), we held that ASA             
          Investerings Partnership was not a valid partnership for tax                
          purposes, and we sustained respondent’s reallocation of                     
          partnership items from a foreign entity to AlliedSignal, Inc.,              
          the tax matters partner in these proceedings.                               
               6The unified partnership procedures have been amended since            
          their effective date of Sept. 3, 1982, and those procedures are             
          now contained in secs. 6221 through 6234.                                   





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