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additional tax liability for petitioner. The adjustments
contained in the 1982 FPAA did.
On August 4, 1988, a petition for readjustment of
partnership items was filed by another partner of Elite (who was
not the tax matters partner), contesting respondent's adjustments
to Elite's 1982, 1983, and 1984 taxable years. Petitioner did
not join in this action, and he never filed an objection on his
own behalf.
On January 16, 1991, a decision was entered by this Court in
Elite's case with respect to its 1982, 1983, and 1984 taxable
years. In accordance with a stipulation of the parties there,
the decision stated that Elite had no basis in its partnership
assets for purposes of depreciation and energy credits.
Respondent later assessed each of Elite's partners additional tax
on account of computational adjustments.
Respondent mailed an affected items notice of deficiency to
petitioner, asserting that he was liable for additions to his
1982 tax on account of his investment in Elite. On May 26, 1992,
petitioner petitioned this Court with respect to this notice. In
essence, petitioner attacks the notice's validity on the ground
that respondent failed to provide him with proper notice of
Elite's proceeding. According to petitioner, respondent failed
to follow established international mailing procedures when she
mailed him the 1982 FPAA. Section 912.42 of the Domestic Mail
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