Harbor Cove Marina Partners Partnership, Robert A. Collins, A Partner Other Than The Tax Matters Partner - Page 24

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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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