- 13 - Kligfelds’ 2000 personal return reported affected items that relate back to the partnership’s 1999 taxable year--i.e., the computation of Kligfeld’s (and Corporation’s) outside basis which then became the adjusted basis of the Inktomi stock distributed and sold in 2000--the limitations period for making partnership adjustments is still open. Discussion Holdings 1 and Holdings 2 were both partnerships under TEFRA--the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324. TEFRA partnerships are subject to special tax and audit rules. See secs. 6221-6234. Each TEFRA partnership, for example, is supposed to designate a tax matters partner (the TMP), to handle the partnership’s administrative issues with the IRS and any resulting litigation. (Corporation is the TMP for Holdings 2.)16 TEFRA aims at determining all partnership items--technically defined in section 6231(a)(3)--at the partnership level; the goal is to have a single point of adjustment for the IRS rather than having to make separate partnership item adjustments on each partner’s individual return. See H. Conf. Rept. 97-760, at 599-601 (1982), 1982-2 C.B. 600, 662-63. If the IRS decides to adjust any partnership items on a 16 Corporation, as TMP, is the petitioner in this case. References to “Kligfeld’s arguments,” “Kligfeld’s position,” and so forth are technically references to Corporation in this capacity.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007