Catherine Chimblo and Estate of Gus Chimblo, Deceased, Catherine Chimblo, Executrix - Page 7

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            introduced by respondent that the FPAAs were properly mailed in                              
            these cases, and we so find.  We find Josephine's and Catherine's                            
            self-serving testimony on this matter to be vague and                                        
            insufficient to overcome respondent's evidence.                                              
                  Having found that petitioners were properly notified of the                            
            partnership proceeding, we lack jurisdiction to redetermine the                              
            deficiencies on which the additions to tax in these cases are                                
            based.  Brookes v. Commissioner, 108 T.C. 1, 5 (1997), on appeal                             
            (9th Cir., March 25, 1997).  The deficiencies are attributable to                            
            partnership items, properly considered solely in the partnership                             
            proceeding.  Saso v. Commissioner, 93 T.C. 730, 734 (1989);                                  
            Maxwell v. Commissioner, 87 T.C. 783, 788 (1986).  Likewise,                                 
            petitioners' arguments that respondent failed to comply with the                             
            applicable periods of limitation at the partnership level are                                
            affirmative defenses that could have been raised in the                                      
            partnership level proceeding and may not be considered by the                                
            Court at the partner level.  Crowell v. Commissioner, supra at                               
            693.                                                                                         
                  The second issue for decision is whether petitioners are                               
            liable for the section 6653(a) additions to tax as determined by                             
            respondent.                                                                                  
                  Section 6653(a)(1) provides for an addition to tax equal to                            
            5 percent of the entire underpayment of tax if any part of the                               
            underpayment is due to negligence or intentional disregard of                                
            rules and regulations.  Section 6653(a)(2) provides for an                                   




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