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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 and
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