- 52 -
Energy Partners v. Commissioner, supra at 744. The second type
requires a determination that must be made at the partner level.
N.C.F. Energy Partners v. Commissioner, supra at 744. In
appropriate circumstances, once the partnership proceeding is
completed, the Commissioner may issue a notice of deficiency to
a partner for additional deficiencies attributable to an
affected item requiring partner-level determinations. Sec.
6230(a)(2)(A)(i); N.C.F. Energy Partners v. Commissioner, supra
at 743-744.
Additional interest is an affected item that requires a
partner-level determination. White v. Commissioner, supra at
212; N.C.F. Energy Partners v. Commissioner, supra at 745.
Section 6230(a)(2)(A)(i) provides that subchapter B shall apply
to any deficiency attributable to affected items that require
partner-level determinations. Subchapter B of chapter 63 sets
forth deficiency procedures in the case of income, estate, gift,
and certain excise taxes.
Section 6213(a) of subchapter B authorizes the Tax Court to
redetermine a deficiency provided a timely petition is filed.
(Hereinafter subchapter B of chapter 63 will be referred to as
the “deficiency procedures”.) Section 6211(a) defines
“deficiency”, in general, as the amount by which the tax imposed
exceeds the sum of the amount of tax shown on the return and the
Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 NextLast modified: May 25, 2011