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(1992)). Thus, the Court does not have jurisdiction to consider
partnership items or affected items while a partnership
proceeding is pending. GAF Corp. & Subs. v. Commissioner, 114
T.C. at 528; Maxwell v. Commissioner, supra at 788.
Petitioner acknowledges that, pursuant to section 6226, “the
Court does not have jurisdiction over disputes regarding
‘partnership items’ and ‘affected items’ as those terms are
defined by * * * [section] 6231(a).” Petitioner then states that
“there has been no determination supporting Respondent’s
allegation that all of the items at issue in the case at bar are
such partnership or partnership affected items”, but he has
provided neither reason nor authority to conclude that any items
in the notice of deficiency are nonpartnership items or are not
affected items requiring partnership-level determinations. The
adjustments made in the notice of deficiency, as quoted above,
are all attributable to adjustments to partnership items or are
affected items, such as miscellaneous itemized deductions that
are deductible only to the extent that they exceed a percentage
of petitioner’s adjusted gross income. See sec. 67(a).
Petitioner claims that dismissal of this case at this time “would
subject Petitioner to the possibility of immediate collection
action without a prior adjudicative hearing.” However,
respondent has conceded, and we hold, that the notice of
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