- 6 - the small partnership exception of section 6231(a)(1)(B)(i); and (2) the parties’ positions regarding the Court’s jurisdiction over the losses petitioners claimed on their returns and the deduction petitioners claimed for legal, accounting, consulting, and advisory fees. In their separate status reports, the parties responded: (1) One of the partners in Alameda is Clarion Forex, which is a disregarded entity and therefore disqualifies Alameda from the small partnership exception; and (2) the Court does not have jurisdiction over the losses or the deductions petitioners claimed on their return because those losses flow directly from partnership items, and since the partnership items had not yet been determined at the partnership level when respondent issued the notice of deficiency, this Court does not have jurisdiction over any of the items in the notice. In addition, petitioners conceded that they were not allowed a deduction for legal, accounting, consulting, and advisory fees. Discussion Applicability of TEFRA TEFRA provisions divide disputes arising from “partnership items” from those arising from “nonpartnership items”. Maxwell v. Commissioner, 87 T.C. 783, 787 (1986). Section 6231(a)(3) provides: (3) Partnership item.--* * * with respect to a partnership, 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 byPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007