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741, 744 (1987). The additions to tax for negligence and
valuation overstatement at issue in this case are examples of
such affected items, and are subject to the normal deficiency
procedures. Sec. 6230(a)(2)(A)(i).
The Court may not adjudicate computational adjustments in an
affected items proceeding such as this one. Saso v.
Commissioner, 93 T.C. 730 (1989). The Court, however, may pass
on whether a partner was properly notified of the partnership
level proceeding, in order to decide the validity of an affected
items deficiency notice. When the notice’s validity is
challenged in the manner in which it is here, the Commissioner
must demonstrate that she has complied with section 6223(a).
Section 6223(a) generally requires the Commissioner to mail each
partner a notice of: (1) The beginning of an administrative
partnership proceeding, and (2) the final partnership
administrative adjustment resulting from that proceeding.
Crowell v. Commissioner, supra at 691-692. Unlike section
6212(a), which governs the issuance of deficiency notices and
states that the Commissioner is authorized to mail such notices
by registered or certified mail, section 6223(a) is silent with
respect to the type of mail to be used for an FPAA.2
2 Respondent’s practice is to send FPAA’s by certified mail.
1 Audit, Internal Revenue Manual (CCH), sec. 4227.47(9), at
7233-21. This practice is similar to respondent’s practice for
mailing notices of deficiency in the United States. Id.
(continued...)
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