3
that the actual partners were the individuals who owned the
corporations.
We decide the following issues:
1. Whether our decision as to the identity of the partners
must be made at the partner level or at the partnership level.
We hold that our decision must be made at the partner level.
Accordingly, pursuant to the request of respondent, we shall
dismiss the proceedings to the extent that they apply at the
partnership level.
2. Whether we have jurisdiction to review the notice of
deficiency issued to the Grigoracis. We hold that we have
jurisdiction to review a portion of the notice of deficiency.
3. Whether the Grigoracis are liable for self-employment
tax. We hold they are not.
4. Whether the Grigoracis are liable for an accuracy-
related penalty under section 6662(a). We hold they are not.
FINDINGS OF FACT
Some facts were stipulated. We incorporate by this
reference the parties’ stipulation of facts and accompanying
exhibits.
TWA is a partnership, and its principal place of business is
in Huntington, West Virginia. TWA provides public accounting
services to its clients. A notice of final partnership
administrative adjustment (FPAA), dated April 14, 2000,
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