Eliane Olson - Page 11

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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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