context: As the United States Supreme Court recognized, the court in a partnership-level TEFRA proceeding is "not required to shut its eyes" to the tax consequences of the court's decision, even if the "formal adjustment" of the partners tax liability will occur at a subsequent proceeding.
citation_a.signal: see
citation_a.identifier: 795 F.3d 1364, 1364
citation_a.parenthetical: "[T]ax is paid only on the partner's individual returns, but [a partnership's] tax treatment is determined and assessed at the partnership level"
citation_a.sentence: See BASR Partnership, 795 F.3d at 1364 (“[T]ax is paid only on the partner’s individual returns, but [a partnership’s] tax treatment is determined and assessed at the partnership level”); see also Keener, 551 F.3d at 1363 (holding that the statute of limitations is a “partnership item” under TEFRA); Prati v. United States, 603 F.3d 1301, 1307 (Fed. Cir. 2010) (“Based on Keener, we hold that the statute of limitations issue is a partnership item.”); see also I.R.C. §§ 6229 (providing the statute of limitations for assessing any tax attributable to a partnership item), 6501 (providing the statute of limitations for assessing tax under the I.R.C.).
citation_b.signal: see also
citation_b.identifier: 603 F.3d 1301, 1307
citation_b.parenthetical: "Based on Keener, we hold that the statute of limitations issue is a partnership item."
citation_b.sentence: See BASR Partnership, 795 F.3d at 1364 (“[T]ax is paid only on the partner’s individual returns, but [a partnership’s] tax treatment is determined and assessed at the partnership level”); see also Keener, 551 F.3d at 1363 (holding that the statute of limitations is a “partnership item” under TEFRA); Prati v. United States, 603 F.3d 1301, 1307 (Fed. Cir. 2010) (“Based on Keener, we hold that the statute of limitations issue is a partnership item.”); see also I.R.C. §§ 6229 (providing the statute of limitations for assessing any tax attributable to a partnership item), 6501 (providing the statute of limitations for assessing tax under the I.R.C.).