“A partnership must report its tax items on an information return, and the partners must report their distributive shares of the partnership's tax items on their own individual returns[.]” Gen. Mills, Inc. v. United States, 957 F.3d 1275, 1278 (Fed. Cir. 2020) (citing 26 U.S.C. §6301(a), §702, §704). Prior to 1982, adjustments to the tax liability of the individual partners based on the operations of the partnership were determined at the individual partners' level.
But the Claims Court may inquire into disputed jurisdictional facts to decide the presence of jurisdiction, and if it does so, we review the court's findings of fact for clear error. General Mills, Inc. v. United States, 957 F.3d 1275, 1284 (Fed. Cir. 2020) (citing Roco-vich v. United States, 933 F.2d 991, 993 (Fed. Cir. 1991)).