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proceedings are completed, respondent is permitted to assess a
computational adjustment against a partner without issuing a
deficiency notice. Sec. 6230(a)(1); N.C.F. Energy Partners v.
Commissioner, 89 T.C. 741, 744 (1987).
The second type of affected item is one that is dependent
upon factual determinations to be made at the individual partner
level. N.C.F. Energy Partners v. Commissioner, supra at 744.
Section 6230(a)(2)(A)(i) provides that the normal deficiency
procedures apply to those affected items which require individual
partner level determinations. Additions to tax under sections
6653(a)(1), 6653(a)(2), and 6661 are affected items requiring
factual determinations at the individual partner level and are
subject to the normal deficiency procedures. N.C.F. Energy
Partners v. Commissioner, supra at 745.
The Court may not adjudicate partnership items or related
computational adjustments in an affected items proceeding such as
this one. Saso v. Commissioner, 93 T.C. 730, 734 (1989). But in
Crowell v. Commissioner, 102 T.C. 683, 691 (1994), we held that
the taxpayers could challenge the validity of the affected items
notice of deficiency on the ground that respondent failed to
properly notify the taxpayer partner of the underlying
partnership level proceeding. As in Crowell, we believe
petitioners' notice argument is tantamount to a motion to dismiss
this case for lack of jurisdiction on the ground that the
affected items notices are invalid.
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