-6-
in WIN Enterprise, LC and Stephens City Chiropractic,
PLC.
2. WIN Enterprise, LC and Stephens City
Chiropractic, PLC are partnerships which are subject to
the unified partnership audit and litigation procedures
set forth in I.R.C. �� 6221 et seq. (the TEFRA partner-
ship procedures).
3. For purposes of computing the overpayment in
this case, petitioner’s partnership items relating to
WIN Enterprise, LC and Stephens City Chiropractic, PLC
have been treated as if they were correctly reported on
petitioner’s income tax returns for the 1996 and 1997
taxable years and they have not been adjusted as part
of this docketed proceeding.
4. The tax treatment of petitioner’s partnership
items relating to WIN Enterprise, LC and Stephens City
Chiropractic, PLC will be resolved in a separate part-
nership proceeding conducted in accordance with the
TEFRA partnership procedures.
5. The adjustments necessary to apply the results
of the TEFRA partnership proceeding described in sub-
paragraph 4 to petitioner, shall be treated as computa-
tional adjustments under I.R.C. � 6231(a)(6) and as-
sessed, credited or refunded accordingly.
6. To the extent that the computation of peti-
tioner’s tax liability which properly reflects the tax
treatment of the partnership items relating to WIN
Enterprise, LC and Stephens City Chiropractic, PLC, as
determined in the TEFRA partnership proceeding de-
scribed in subparagraph 4, would also result in a
change in petitioner’s tax liability attributable to
nonpartnership items, as previously determined in this
docketed proceeding, such change may be treated as a
computational adjustment under I.R.C. � 6231(a)(6) and
assessed, credited or refunded accordingly.
At the time the parties executed the parties’ stipulation in
petitioner’s non-TEFRA case at docket No. 7901-00, the Court had
already dismissed for lack of jurisdiction the TEFRA case at
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