- 8 -
(11th Cir. 1993). Indeed, we have expressly held that we lack
jurisdiction to consider computational adjustments in a
subsequent affected items proceeding to redetermine additions to
tax. However, in Crowell v. Commissioner, 102 T.C. 683 (1994),
we held that a taxpayer 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.
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