- 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.
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