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Century Industries plus any guaranteed payments he received
during those years. Respondent’s Opening Brief at 796.
Respondent issued a notice of final partnership
administrative adjustment (FPAA) to Century Industries
reallocating some of the partnership’s 1986 income to Kanter. No
FPAA was issued to Century Industries for 1983 and 1984. In
effect, respondent disregarded all of the other partners in
Century Industries except Kanter and Weisgal.
OPINION
A. The Parties’ Arguments
Petitioners contend: (1) All of Century Industries’
partners during 1981 to 1984 and 1986 should be respected as
partners for tax purposes; (2) no additional partnership income
should be attributed to Kanter as his taxable income; and (3) the
Court lacks jurisdiction to review respondent’s determinations
for 1983, 1984, and 1986 in the context of these deficiency cases
because Century Industries was a partnership subject to the
unified partnership administrative and litigation provisions
found in subchapter C of chapter 63 of subtitle F of the Internal
Revenue Code enacted as part of the Tax Equity and Fiscal
Responsibility Tax Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat.
324.
Respondent asserts that, for tax purposes, Kanter and
Weisgal are the only two persons who should be recognized as
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