- 12 - Congress. See sec. 7442; see also GAF Corp. & Subs. v. Commissioner, 114 T.C. 519, 521 (2000). We have jurisdiction to redetermine a deficiency if a valid notice of deficiency is issued by the Commissioner and if a timely petition is filed by the taxpayer. See GAF Corp. & Subs. v. Commissioner, supra at 521. We may decide issues only to the extent of our jurisdiction, and the fact that the parties agree that we lack jurisdiction to decide the issue concerning the accuracy-related penalties does not necessarily mean that we indeed lack jurisdiction to decide that issue. See Charlotte’s Office Boutique, Inc. v. Commissioner, 121 T.C. 89, 102-104 (2003), affd. 425 F.3d 1203 (9th Cir. 2005). Partnerships are not subject to Federal income tax. See sec. 701. They are required, however, to file annual information returns reporting their partners’ distributive shares of income, gain, loss, deductions, or credits. See sec. 6031; see also Randell v. United States, 64 F.3d 101, 103 (2d Cir. 1995). The partners are required to report their distributive shares of those items on their personal Federal income tax returns. See secs. 701, 702, 703, and 704. Before 1982, the Commissioner and the courts were required to adjust partnership items at the partner level. See Randell v. United States, supra at 103. Because this requirement resulted in a duplication of administrative and judicial resources andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007