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On June 10, 1993, the Court entered an Order and Order of
Dismissal and Decision (the final order) in the partnership
proceeding. The final order dismissed the partnership proceeding
and sustained respondent's adjustments as determined in the FPAA.
On August 29, 1994, a computational adjustment was assessed
against petitioner. The computational adjustment was made to
record the change in petitioner's tax liability resulting from
the Court's final order dismissing the partnership proceeding and
sustaining the partnership items relating to Computer Graphics
for 1982. See sec. 6226(h).
The Affected Items Proceeding
On August 26, 1994, respondent mailed petitioner a notice of
deficiency in which respondent determined that, for 1982,
petitioner was liable for additions to tax for negligence under
section 6653(a)(1) and 6653(a)(2) and an addition to tax for a
substantial understatement of income tax under section 6661.
These additions to tax are affected items because they are based
on tax owing by petitioner as a result of adjustments to
partnership items appearing on Computer Graphics' partnership
return for 1982.
Petitioner timely filed a petition for redetermination with
respect to the affected items notice of deficiency. In the
petition, petitioner claims that she is entitled to relief as an
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