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with petitioner, the fact remains that respondent complied with
the statutory requirements in notifying Mr. Olson about the
Computer Graphics' partnership proceeding and, thus, is deemed to
have properly notified petitioner of such proceeding.
Because petitioner was properly notified of the partnership
level proceeding regarding Computer Graphics, we hold that the
affected items notice of deficiency is valid as to her.
Jurisdiction Regarding the Innocent Spouse Defense
In her petition, petitioner claims that she is entitled to
innocent spouse relief under section 6013(e) with respect to not
only the additions to tax determined in the affected items notice
of deficiency, but also the computational adjustment that
respondent assessed against her on August 29, 1994.
Respondent acknowledges that petitioner is entitled to raise
the innocent spouse defense with respect to the additions to tax
determined in the affected items notice of deficiency. However,
respondent contends that this Court lacks jurisdiction in an
affected items proceeding to consider the innocent spouse defense
with respect to a computational adjustment. We agree with
respondent.
As previously mentioned, this Court has no jurisdiction to
consider challenges to computational adjustments in an affected
items proceeding. Bradley v. Commissioner, supra; Saso v.
Commissioner, supra; Maxwell v. Commissioner, supra, Palmer v.
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