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the Secretary provide that, for purposes of this
subtitle, such item is more appropriately determined at
the partnership level than at the partner level.
If the tax treatment of a partnership item is at issue, the
statute generally requires the matter to be resolved at the
partnership level. Sec. 6221; Maxwell v. Commissioner, supra at
787-788. Further, deficiencies attributable to “affected items”
may not be assessed until the related partnership proceeding is
completed. See sec. 6225(a); GAF Corp. & Subs. v. Commissioner,
114 T.C. 519, 525 (2000). An affected item is “any item to the
extent such item is affected by a partnership item.” Sec.
6231(a)(5). An affected item is peculiar to a partner’s own tax
posture. Maxwell v. Commissioner, supra at 790.
Respondent asserts that all the adjustments in the notice of
deficiency consist of affected items that depend on partnership-
level determinations. Respondent asserts that the adjustments in
the notice of deficiency relating to petitioners’ share of the
partnership loss is a partnership item under section
301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs. Respondent
further argues that adjustment for the amount of loss petitioners
sustained for their sale of securities depends on a determination
of petitioners’ basis in Alameda, which petitioners used to
compute their basis in the securities under section 732(b).
Under section 301.6231(a)(5)-1(b), Proced. & Admin. Regs., the
basis of a partner’s interest in a partnership is an affected
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