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to all taxable years of a partnership beginning after
September 3, 1982. Sparks v. Commissioner, 87 T.C. 1279, 1284
(1986); Maxwell v. Commissioner, 87 T.C. 783, 789 (1986). A
partnership item is any item required to be taken into account
for the partnership’s taxable year under any provision of
subtitle A to the extent regulations prescribed by the Secretary
provide that, for purposes of subtitle A, such item is more
appropriately determined at the partnership level than at the
partner level. Sec. 6231(a)(3). Partnership items normally
include each partner’s proportionate share of the partnership’s
aggregate items of income, gain, loss, deduction, or credit.
Sec. 301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs.
Partnership items are distinguished from affected items,
which are defined in section 6231(a)(5) as any item to the extent
such item is affected by a partnership item. White v.
Commissioner, 95 T.C. 209, 211 (1990). The first type of
affected item is purely a computational adjustment made to record
the change in a partner’s tax liability resulting from the proper
treatment of partnership items. Sec. 6231(a)(6); White v.
Commissioner, supra at 211. Once the decision in a partnership-
level proceeding is final, the Commissioner is permitted to
assess a computational adjustment against a partner without
issuing a notice of deficiency. Secs. 6225, 6230(a)(1); N.C.F.
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Last modified: November 10, 2007