id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-353	McMahon, Jr., Martin J.; Shepard, Ira B.; Simmons, Daniel L.	Recent Developments in Federal Income Taxation: The Year 2009	2022	184	.pdf	application/pdf	82693	3711	54	Judge Vasquez held that the application to a partner of the loss limitation rules of §§ 704(d) and 465 are affected items that require a partner-level determination. A notice of deficiency to a partner based on the application of the loss limitation rules of §§ 704(d) and 465 was not issued prematurely and was valid, even though IRS had neither issued a notice of final partnership administrative adjustment for the partnership nor accepted the partnership’s return as filed for the year.	cache/ftr-353.pdf	txt/ftr-353.txt