partnership-related item
(B) Partnership-related item The term “partnership-related item” means— (i) any item or amount with respect to the partnership (without regard to whether or not such item or amount appears on the partnership’s return and including an imputed underpayment and any item or amount relating to any transaction with, basis in, or liability of, the partnership) which is relevant (determined without regard to this subchapter) in determining the tax liability of any person under chapter 1, and (ii) any partner’s distributive share of any item or amount described in clause (i).