Bergford

This appeal requires us to decide whether the arrangement between owners of computer equipment and the manager of a sale-leaseback program to finance, purchase, lease, and remarket the equipment is a part *167 nership subject to the unified audit and litigation provisions for partnership items under §§ 6221-6233 of the Internal Revenue Code. The five actions that are the subject of this consolidated appeal were initiated by taxpayers in the Tax Court'seeking redetermina-tions of the deficiencies in federal income tax and additions to tax determined by the Commissioner. 1 The Tax Court held that it lacked jurisdiction to hear the individual petitions because taxpayers’ venture was a partnership, and no Final Partnership Administrative Adjustment (FPAA) had been issued by the Internal Revenue Service.

Our jurisdiction is based on 26 U.S.C. § 7482 . We review the Tax Court’s determination of its jurisdiction de novo. Scar v. Commissioner, 814 F.2d 1363, 1366 (9th Cir.1987). We agree that the taxpayers’ relationship with their co-participants and the manager falls within the Internal Revenue Code’s definition of “partnership,” and that the Tax Court lacked jurisdiction over…