Robert Michael Garner - Page 2

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               (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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