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partnership proceeding”. (Emphasis added.)) established that
respondent misled petitioner. These facts, however, do not
override the mandate of section 6221 that “the tax treatment of
any partnership item * * * shall be determined at the partnership
level.” Maxwell v. Commissioner, 87 T.C. 783, 787-788 (1986).
Respondent complied with the partnership audit and
litigation procedures and, upon completion of the partnership-
level proceeding, assessed a computational adjustment against
petitioner. See secs. 6223, 6225(a)(2), 6230(a)(1), 6231(a)(6);
Brookes v. Commissioner, 108 T.C. 1, 5 (1997). Petitioner had
the opportunity, in the partnership-level proceeding, to
challenge the partnership items, but he failed to do so.
Accordingly, petitioner is precluded from challenging those items
in this proceeding. See secs. 6221, 6226; Brookes v.
Commissioner, supra at 5-7.
Petitioner further contends that respondent’s determinations
relating to this proceeding are untimely. We disagree.
Respondent sent petitioner the notice of deficiency relating to
this proceeding prior to the expiration of the period prescribed
by section 6229(d). Sec. 6229(d)(1) and (2) (providing that the
mailing of an FPAA suspends the running of the 3-year limitations
period until 1 year after the Court’s decision relating to a
partnership-level proceeding becomes final); Aufleger v.
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