Peter D. Adkison - Page 8




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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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