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(1986). This is so even though the FPAA contained no changes
made by respondent. See Univ. Heights at Hamilton Corp. v.
Commissioner, 97 T.C. 278, 282 (1991).
Congress promulgated the TEFRA partnership unified audit and
litigation provisions of sections 6221 through 6234 intending to
simplify and streamline the audit, litigation, and assessment
procedures with respect to partnerships and their partners.
These provisions centralized the tax treatment of partnership
items and resulted in equal treatment for partners through the
uniform adjustment of each partner’s tax liability in a single,
unified proceeding. Chimblo v. Commissioner, 177 F.3d 119,
120-121 (2d Cir. 1999), affg. T.C. Memo. 1997-535; Kaplan v.
United States, 133 F.3d 469, 471 (7th Cir. 1998). Because the
income of a partnership is not subject to Federal income tax at
the partnership level, but is passed through and taxed to the
partners, multiple proceedings were required before TEFRA to
address the tax treatment of partnership items. Chimblo v.
Commissioner, supra at 121. Congress in enacting TEFRA intended
that “the tax treatment of items of partnership income, loss,
deductions, and credits will be determined at the partnership
level in a unified partnership proceeding rather than separate
proceedings with the partners.” H. Conf. Rept. 97-760, at 600
(1982), 1982-2 C.B. 600, 662.
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