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position with respect to Mr. Blonien’s share of items from
Whitman & Ransom that was inconsistent with Whitman & Ransom’s
return.
If a partner takes a position on his return inconsistent
with the partnership’s position on its return and properly files
a Form 8082 calling attention to the inconsistency, the
Commissioner has the option of (1) converting all partnership
items arising from that partnership into nonpartnership items and
resolving them at the partner level by so notifying the partner
under section 6231(b)(1)(A), or (2) determining the items at the
partnership level while allowing the inconsistent treatment
pending the conclusion of the partnership-level proceedings.
Sec. 301.6222(b)-2T(a), Temporary Proced. & Admin. Regs., 52 Fed.
Reg. 6782 (Mar. 5, 1987).
A partner who receives a Schedule K-1 and fails to notify
the Commissioner of inconsistent treatment by filing a Form 8082
is bound by the partnership’s position on its return. The
Commissioner may make a computational adjustment (without
following the deficiency procedures) to make the partner’s return
consistent with the partnership’s return. Sec. 6222(c); sec.
301.6222(b)-2T(a), Temporary Proced. & Admin. Regs., supra.
On no return that is part of the record in this case did
petitioners notify respondent that Mr. Blonien was not a partner.
Petitioners led respondent to believe that Mr. Blonien was a
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