defenses that may apply or to challenge the amount of the computational adjustment. I.R.C. § 6230(c)(4) (emphasis added). 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. See Woods, 134 S.Ct. at 666. The statute of limitations defense successfully raised by BASR in this case was held to be a partnership-level item by our appellate court. 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>); Prati v. United States, 603 F.3d 1301, 1307
holding that the statute of limitations is nonjurisdictional and defendant expressly waived it observing in dicta that a statute of limitations defense should be raised no later than the trial holding that duress toll to statute of limitations under state law had no application to federal rico statute of limitations holding that the aedpa statute of limitations is not jurisdictional holding that the running of the statute of limitations is an affirmative defense holding that the statute of limitations is a partnership item under tefra