- 2 - (2) he did not receive notice of it in enough time to allow him to join in E's proceeding. Robert M. Garner, pro se. Diane D. Helfgott, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LARO, Judge: Robert M. Garner petitioned the Court to redetermine respondent's determinations of additions to his 1982 Federal income tax. Respondent determined that petitioner was liable for a $487 addition to tax for negligence under section 6653(a)(1) and a $2,924 addition to tax for valuation overstatement under section 6659(a). Respondent also determined that petitioner was liable for an addition to tax for negligence under section 6653(a)(2). Respondent's determinations, which are reflected in an affected items notice of deficiency mailed to petitioner on February 26, 1992, flow from petitioner's investment in a partnership named "Elite Energy Systems Limited Partnership" (Elite). Following concessions, we must decide whether the affected items notice of deficiency is valid. We hold it is not.1 Unless 1 Based on our holding, we do not decide the other issue in dispute; namely, whether petitioner is liable for the additions to tax determined by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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