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inconsistent results among partners, Congress enacted the unified
audit and litigation procedures of the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 401, 96
Stat. 648, intending to remove the substantial administrative
burden occasioned by duplicative audits and litigation and to
provide consistent treatment of partnership income, gain, loss,
deductions, and credits among all partners in the same
partnership. See Randell v. United States, supra at 103;
H. Conf. Rept. 97-760, at 599-600 (1982), 1982-2 C.B. 600,
662-663. The TEFRA procedures determine the proper treatment of
“partnership items” at the partnership level in a single, unified
audit and judicial proceeding. See Randell v. United States,
supra at 103; H. Conf. Rept. 97-760, supra at 599-600, 1982-2
C.B. at 662-663. In this context, the term “partnership items”
includes any item of income, gain, loss, deduction, or credit
that the Secretary has determined is “more appropriately
determined at the partnership level than at the partner level.”
Sec. 6231(a)(3); see also sec. 301.6231(a)(3)-1(a), Proced. &
Admin. Regs.
Where the Commissioner disagrees with a partnership’s
reporting of a partnership item, the Commissioner must mail an
FPAA before assessing the partners with any amount attributable
to that item. See secs. 6223(a)(2), (d)(2), 6225(a). The TMP
has 90 days from the date of the mailing of the FPAA to contest
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