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return. Bob Hamric Chevrolet, Inc. v. United States, supra at
512.
We are not persuaded that the cases relied on by petitioner
support the conclusion that the NOL carryforward adjustments in
question are properly characterized as affected items that must
be resolved in a partner-level proceeding. Rather, we are
satisfied, based on the record presented, that those adjustments
satisfy the definition of an affected item subject to
computational adjustment. Sec. 6231(a)(6); White v.
Commissioner, 95 T.C. 209, 211 (1990). Indeed, as was the case
in Bob Hamric Chevrolet, Inc. v. United States, supra, counsel
for petitioner concedes that there is no dispute as to the
computations that respondent made in this case.
In view of the foregoing, and under the facts presented, we
see no merit in petitioner's contention that the NOL carryforward
adjustments in this case must be the subject of an affected items
notice of deficiency.
In order to reflect the foregoing,
An appropriate order
will be issued.
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