§6231 — Notice of proceedings and adjustment

6231(a)(6) defines the term "computational adjustment" to mean "the change in the tax liability ofa partner which properly reflects the treatment under * * * [the TEFRA partnership rules] ofa partnership (continued...) -28- [*28] Congress enacted section 6234 to "overrule[]" this Court's decision in Munro v.

6231(a)(6) defines the term "computational adjustment" to mean "the change in the tax liability ofa partner which properly reflects the treatment under * * * [the TEFRA partnership rules] ofa partnership (continued...) -28- [*28] Congress enacted section 6234 to "overrule[]" this Court's decision in Munro v.

The Commissioner argues that equitable estoppel applies because he “was not in possession of all relevant facts as to whether an election 9 Petitioner also argues that section 6231(g)(1) (TEFRA) is inapplicable to this case. Section 6231(g) extends the TEFRA procedures when they otherwise might not apply if the Commissioner reasonably determines from a partnership return that TEFRA applies. But section 6231(g) does not apply on the facts of this case because the Commissioner’s determination to a

The issue for decision is whether respondent, in reliance on section 6231(g)(2),2 reasonably determined that TEFRA procedures did not apply to Dani, LLC, for the 2011 and 2012 tax years. Section 6231(g)(2) provides: "If, on the basis ofa partnership return for a taxable year, the Secretary reasonably determines that this subchapter [TEFRA] does not apply to such partnership for such year but such determination is erroneous, then the provisions ofthis subchapter shall not apply to such partnershi

The parties filed opening and answering briefs addressing their positions as to whether section 6231(g)(2) applies under the facts ofthis case. Respondent argues that section 6231(g)(2) does not apply because the IRS did not determine that Stone Canyon was not subject to TEFRA and that, ifthe IRS had made such a determination, the determination would not have been reasonable.

Pursuant to section 6231(a)(1)(B)(ii), petitioner elected to be covered under TEFRA.

We also note that, pursuant to section 6231(a)(7) and section 301.6231(a)(7)-1(p) and (q), Proced.

We hold that the Tax Court had no jurisdiction to determine that Petaluma's partners had no outside basis in the disregarded partnership.

Under section 6231(g)(1), when the Commissioner erroneously determines that TEFRA applies to a non-TEFRA partnership, the partnership will be subject to TEFRA so long as that determination was reasonable on the basis ofthe partnership's tax return. When the Commissioner makes a reasonable but erroneous determination on the basis ofa partnership return that TEFRA applies to a small partnership, a partnership that should be subject to the normal deficiency procedures will instead be subject to the

Partner Must Have Interest in Outcome.-- (1) In order to be party to action.--Subsection (c) shall not apply to a partner after the day on which-- (A) the partnership items of such partner for the partnership taxable year became nonpartnership items by reason of 1 or more of the events described in subsection (b) of section 6231, or (B) the period within which any tax attributable to such partnership items may be assessed against that partner expired.

ers, including the LLCs, created separate entities classified as partnerships for Federal income tax purposes (with the LLCs as partners therein), it is clear that, as LLCs taxable as pahnerships, the LLCs would constitute "pass-thru" partners under section 6231 a)(9). - 22 - [*22] B. Jurisdiction Over and Definitions ofPartnership Items and Affected Items Section 6221 provides: SEC. 6221. TAX TREATMENT DETERMINED AT PARTNERSHIP LEVEL. Except as otherwise provided in this subchapter, [e.g., sect

The Court of Appeals accepted the Government’s concession without any discussion of section 6233 or 6231 or the regulations under section 6231 upon which the Tax Court had relied.

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

porary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).¹9 The ¹8 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1) (A). ¹9 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulatio

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

emporary Proced. & Admin. Regs, 52 Fed. Reg. 6791 (Mar. 5, 1987).19 The 18 The period of limitations for a specific partner may also be extended by an agreement between the IRS and that partner. See sec. 6229(b)(1)(A). 19 Temporary regulations under sec. 6231 concerning the designation, selection and termination of a TMP were issued in 1984 and 1987, and generally applied to all partnership taxable years beginning after Sept. 3, 1982. Virtually identical provisions are made by the final regulati

f the events described in section 6231(b). Section 6231(b)(1)(D) provides, in part, that for purposes of the TEFRA provisions the partnership items of a partner shall become nonpartnership items as of the date a change occurs under subsection (c) of section 6231. Section 6231(c) provides that in certain special enforcement areas the Secretary may provide by regulations for the conversion of a partner's partnership items into nonpartnership items. Computer Programs Lambda, Ltd. v. Commissioner, 8

f the events described in section 6231(b). Section 6231(b)(1)(D) provides, in part, that for purposes of the TEFRA provisions the partnership items of a partner shall become nonpartnership items as of the date a change occurs under subsection (c) of section 6231. Section 6231(c) provides that in certain special enforcement areas the Secretary may provide by regulations for the conversion of a partner's partnership items into nonpartnership items. Computer Programs Lambda, Ltd. v. Commissioner, 8

f the events described in section 6231(b). Section 6231(b)(1)(D) provides, in part, that for purposes of the TEFRA provisions the partnership items of a partner shall become nonpartnership items as of the date a change occurs under subsection (c) of section 6231. Section 6231(c) provides that in certain special enforcement areas the Secretary may provide by regulations for the conversion of a partner's partnership items into nonpartnership items. Computer Programs Lambda, Ltd. v. Commissioner, 8

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be - 10 - . treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent with respect to such items. Sec. 6231(b)(1)(C). The

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent with respect to such items. Sec. 6231(b)(1)(C). The classific

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be - 10 - . treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent . with respect to such items. Sec. 6231(b)(1)(C). Th

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent - 22 - with respect to such items. Sec. 6231(b)(1)(C). The cl

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent with respect to such items. Sec. 6231(b)(1)(C). The classific

6226(d) Partner Must Have Interest in Outcome.-- (1) In order to be party to action.-- Subsection (c) shall not apply to a partner after the day on which-- (A) the partnership items of such partner for the partnership taxable year became nonpartnership items by reason of 1 or more of the events described in subsection (b) of section 6231, or (B) the period within which any tax attributable to such partnership items may be assessed against that partner expired.

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent with respect to such items. Sec. 6231(b)(1)(C). The classific

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent with respect to such items. Sec. 6231(b)(1)(C). The classific

to a partnership action. Sec. 6226(c). However, a partner is not a party if he or she does not have an interest in the outcome of the proceeding because such partner's partnership items have become nonpartnership items pursuant to subsection (b) of section 6231. Sec. 6226(d). A partner's partnership items will be treated as nonpartnership items as of the date on which the partner enters into a settlement agreement with the respondent - 22 - with respect to such items. Sec. 6231(b)(1)(C). The cl

Congress amended the period to rectif[y] the unintended conflict between section 6231 (barring the Secretary from issuing the notice of final partnership adjustment earlier than the expiration of the 270 days after the notice of a proposed adjustment) and section 6235 (requiring that a notice of final partnership adjustment be filed no later than 270 days after the notice of proposed adjustment in the case of a partners

§ 301.6231(a)(3)-1(a)(1)(i). And the FPAA disallows a $665,500 loss deduction reported by Corning Place on the ground that the easement-related expenses were not properly deductible under section 162(a). At bottom, petitioner appears to argue that the FPAA is invalid because Millenia and its agents claimed the charitable contrib

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

n to determine whether we have jurisdiction. Determining whether we havejurisdiction in this case requires that we decide whether EP is a "partnership" subject to TEFRA procedures. Ifso, the disallowed loss deductions are "partnership item[s]", see sec. 6231; sec. 301.6231(a)(3)-1(a)(1)(i), Proced. & Admin. Regs., and section 6221 would deprive us ofjurisdiction over them in this deficiency proceeding. Consistent with the general scheme ofTEFRA, where a taxpayer in a non-TEFRA deficiency - 13 -

Regulations issued under section 6231 explain that there are various types of"computational adjustments," some ofwhich require partner-level determina- tions and some ofwhich do not.

he only issue in this case is whether net proceeds oftwo ofSLRD's sales in 2012 should be treated as capital gains or ordinary income. Items ofgain ofthe partnership are partnership items. Sec. 301.6231(a)(3)- 1(a)(1)(i), Proced. & Admin. Regs.; see sec. 6231. Therefore, we havejurisdiction over the issue presented in this case. - 9 - [*9] asset is "property held by the taxpayer (whether or not connected with his trade or business)" but excludes, among other things, "inventory" and "property hel

Section 6231(g)(2), for example, provides that TEFRA procedures shall not apply ifthe Secretary "reasonably determines" (correctly or not) that they do not apply.

Based on clear precedent we explained that Roth IRAs are trusts, and that section 6231 makes trusts a type of"pass-thru partner." We denied Block's motion.

Based on clear precedent we explained that Roth IRAs are trusts, and that section 6231 makes trusts a type of"pass-thru partner." We denied Block's motion.

Based on clear precedent we explained that Roth IRAs are trusts, and that section 6231 makes trusts a type of"pass-thru partner." We denied Block's motion.

Based on clear precedent we explained that Roth IRAs are trusts, and that section 6231 makes trusts a type of"pass-thru partner." We denied Block's motion.

However, taxpayers are permittedto deduct the value ofa contribution ofa partial interest in propertythat constitutes a - 11 - "qualified conservation contribution" as defined in section 170(h)(1).

'The Court assumes that respondent determined that the partnership involved in the 2000 transaction was a small partnership within the meaning of the small partnership exception, see sec.

Temporary regulations under section 6231 take a similar approach.

Temporary regulations under section 6231 take a similar approach.

that he timely assessed petitioners' t x liability within the ;" period allowed by section 6229(a) and " (d) after the Court's l decision became-'final . Petitioners assert-that the relevant partnership items converted to nonpartnership items under section 6231 (b). (1) (C) !I by means of a settlement agreement betwe e respondent . Petitioners argue that M settlement agreement with respondent on or about September 301, 1991. .,; .through correspondence exchange between Mr . Lerner,.. Greenwich'

Exceptions to Application of TEFRA Procedures " For completeness and to prepare for concluding observations in the Afterword about problems of judicial administration created by TRA 1997 and the temporary regulation, we note two circumstances under section 6231 in which what would have otherwise been partnership items may be treated as nonpartnership items .

Section 6231,(a)(3) defines the term "partnership item" as any item required to be taken .into account for the partnership's taxable year under any provision of subtitle A of the Code to the extent the regulations provide that such item is more appropriately determined at the partnership level than at the partner level . ; The loss claimed on Count

See generally secs .

(d) Partner Must Have Interest in Outcome .-- (1) In order to be party to,action.-- Subsection (c) shall not apply to a partner :after the day on which-- .(A) the partnership items of such partner for the partnership taxable year became nonpartnership items by reason of 1 or ; more of the events described in subsectio n (b) of section 6231, o r (B) the period within which any tax attributable to .such partnership items may be assessed against that partner expired .

— Subsection (c) shall not apply to a partner after the day on which— (A) the partnership items of such partner for the partnership taxable year became nonpartnership items by reason of 1 or more of the events described in subsection (b) of section 6231, or (B) the period within which any tax attributable to such partnership items may be assessed against that partner expired.

(d) Partner Must Have Interest in Outcome .-- (1) In order to be party to action .-- Subsection (c) shall not apply to a partner after the day on which-- (A) the partnership items of such partner for the partnership taxable year became nonpartnership items by reason of 1 or more of the events described in subsection (b) of section 6231, or (B) the period within which any tax attributable to such partnership items may be assessed against that partner expired .

We base this conclusion on the definition of "partnership item" in section 6231 ("required to be taken into account for the partnership's taxable year"), our interpretation of the pertinent regulations, in light of the statute (an approach which makes it unnecessary for us to rule on petitioners' contention that the regulations are invalid), and the application of the statute and regulations in the decided cases .

783, 787 (1986) (citing section 6231 (a)(3) and (4)) .

* * * Section 6231 is one of a group of provisions concerning the tax treatment of partnership items that was added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 5Petitioner’s alternative ground is that this proceeding is time barred by sec. 6501(a). The same ground was raised in the partnership case. See Rhone-Poul

* * * Section 6231 is one of a group of provisions concerning the tax treatment of partnership items that was added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648 (TEFRA partnership provisions). For income tax purposes, partnerships are not taxable entities. See sec. 701 (reflec

— Subsection (c) shall not apply to a partner after the day on which— (A) the partnership items of such partner for the partnership taxable year became non-partnership items by reason of 1 or more of the events described in subsection (b) of section 6231, or (B) the period within which any tax attributable to such partnership items may be assessed against that partner expired.

- 10 - "partnership items" for purposes of section 6231.8 Subsequently, the case was submitted on the basis of the record.

- 10 - "partnership items" for purposes of section 6231.8 Subsequently, the case was submitted on the basis of the record.

, in pertinent part, that section 6226(c) shall not apply to a partner "after the day" on which the partnership items of such partner for the particular partnership taxable year become nonpartnership items by reason of one of the events described in section 6231. A settlement agreement between the Secretary and a partner is among the events causing the conversion of partnership items into nonpartnership items. Sec. 6231(b)(1)(C). Section 6224(c) provides that in the absence of a showing of fraud

- 10 - "partnership items" for purposes of section 6231.8 Subsequently, the case was submitted on the basis of the record.

- 10 - "partnership items" for purposes of section 6231.8 Subsequently, the case was submitted on the basis of the record.

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga

Ltd. Partnership 480,813 - 3 - Ironwood Manufacturing Ltd. Partnership 918,765 Vail Commerce Center Ltd. Partnership 417,156 Petitioners' motion asserts that none of the above adjustments involves a "partnership item" as that phrase is defined by section 6231. Therefore, petitioners' motion asks the Court to dismiss all of the subject cases on the ground that the Court does not have jurisdiction to readjust nonpartnership items in these proceedings commenced under the unified partnership litiga